James Ryan Taylor and Steven Vincent Smith v. United States
CriminalProcedure JusticiabilityDoctri
Does the good-faith exception to the exclusionary rule apply to evidence seized under an invalid warrant if agents knowingly misrepresented the fact that made the warrant invalid—the geographic reach of a technologically complex search?
QUESTIONS PRESENTED When law enforcement agents violate the Fourth Amendment because they reasonably misunderstand their authority, the evidence they seize ordinarily is still admissible. But when they violate the Fourth Amendment by engaging in “deliberate, reckless, or grossly negligent conduct, or in some circumstances recurring or systemic negligence,” then “the exclusionary rule serves to deter” similar conduct in the future. Herring v. United States, 555 U.S. 135, 144 (2009). This case turns on the admissibility of evidence government agents seized pursuant to a warrant they obtained after misrepresenting a crucial fact. FBI agents applied to a magistrate judge for a warrant to search computers anywhere in the world, knowing that Federal Rule of Criminal Procedure 41(b) might not allow such a broad search. Their application obscured the search’s geographic scope, prominently claiming they would search property in the Eastern District of Virginia and never clearly saying they would search property outside the district. The court of appeals held that the warrant was invalid because of its geographic scope, but that the evidence seized during the search was admissible under the “good-faith exception” to the exclusionary rule. The Petitioners present this question: Does the good-faith exception to the exclusionary rule apply to evidence seized under an invalid warrant if agents knowingly misrepresented the fact that made the warrant invalid—the geographic reach of a technologically complex search?