State v. Nunez

Justice KIDWELL,

specially concurring.

In reversing the district court’s order of suppression, the majority finds the warrant was valid as issued. I concur fully in the analysis of the majority opinion, however, I feel this Court, as an alternative basis, should formally adopt the Leon “good faith” exception to Idaho’s exclusionary rule. See United States v. Leon, 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984). In doing so, I would overrule or modify State v. Guzman, 122 Idaho 981, 992-93, 842 P.2d 660, 671-72 (1992) to the extent that case rejected the good faith exception under Idaho’s exclusionary rule pursuant to Art. 1, § 17 of the Idaho Constitution.

In Guzman, this Court rejected the Leon good faith exception on the basis of the U.S. Supreme Court’s narrow justification for the exclusionary rule, which is to deter police misconduct. Id. The Guzman Court ruled that the good faith exception was incompatible with Idaho’s independent exclusionary rule because Idaho’s exclusionary rule does much more than just deter police conduct. The Guzman Court recognized the purpose of the Idaho exclusionary rule is to: (1) provide an effective remedy to citizens whose constitutional right to be free from unreasonable search and seizure has been violated; (2) deter police misconduct in obtaining evidence; (3) promote care in the warrant issuing process; (4) avoid further constitutional violations by the judiciary due to further consideration of illegally obtained evidence; and (5) maintain judicial integrity. Id. Additionally, the Guzman Court rejected the good faith exception based on the Leon Court’s reasoning that the decision to apply the exclusionary rule depends on whether the goal of police deterrence would be furthered. Id. The Guzman Court reasoned that regardless of whether police misconduct would be deterred by applying the exclusionary rule, it should always be applied in cases where evidence is seized illegally.

*644The good faith exception to the exclusionary rule prevents suppression of evidence seized in good faith reliance on a warrant, even if the warrant is not supported by probable cause in violation of the Fourth Amendment. Id. The Leon Court reasoned that in such a situation there was no police misconduct, and as a result, nothing to deter. Id. (citing United States v. Leon, 468 U.S. 897, 921, 104 S.Ct. 3405, 3419, 82 L.Ed.2d 677, 697 (1984)). The Leon Court further reasoned that since deterrence is the only justification for the exclusionary rule, it has no application in instances where the police did not act illegally. Id.

It is my position that adoption of the good faith exception would do no injury to any of the stated purposes of the Idaho exclusionary rule. Application of the good faith exception is limited in that it requires good faith reliance. Law enforcement officials may not recklessly procure a warrant and then hope it will be upheld based on the good faith exception. The good faith exception can be applied in cases where it is warranted without compromising the integrity of any of the stated purposes behind the Idaho exclusionary rule. Under Idaho’s exclusionary rule, evidence obtained illegally will be suppressed, as the Guzman Court advocates. As a result, I would formally adopt the Lean good faith exception in order to clarify when evidence is not subject to exclusion, as in cases such as the one before the Court.