Officers conducted a vehicle search under the prevailing law at that time (New York v. Belton), which led to the arrest of the defendant. The defendant appealed his subsequent conviction. Two years after the defendant’s arrest, the Supreme Court modified its Belton ruling (Arizona v. Gant).
Whether searches conducted in compliance with prevailing law that is later overruled are subject to the exclusionary rule?
No. The purpose of the exclusionary rule is to discourage law enforcement
misconduct, which would not be furthered by excluding evidence in these cases.
The exclusionary rule is a Court created mechanism to “deter future Fourth Amendment violations.” The Court stated “[F]or exclusion to be appropriate, the deterrence benefits of suppression must outweigh its heavy costs.” As in this case, where deterrence of officer misconduct is not obtainable, the Court will refrain from applying the exclusionary rule. Citing Herring v. United States, 555 U.S. 135 (2009), the Court explained the exclusionary rule should only be applied to obtain “meaningful deterrence, and culpable enough to be worth the price paid by the justice system.”
564 U.S. 229, 131 S. Ct. 2419 (2011)