ns, as being ineffective in ensuring compliance with the Fourth Amendment.8 Although the Mapp Court stated that the exclusionary rule was an essential part of both the Fourth and Fourteenth Amendments, subsequent Supreme Court decisions have abandoned that position. For example, in United States v. Leon 9 the Supreme Court stated that "[t]he Fourth Amendment contains no provision expressly precluding the use of evidence obtained in violation of its commands, and an examination of its commands and purposes makes clear that using fruits of a past unlawful search or seizure 'works no new Fourth Amendment wrong'"10 In United States v. Calandra,11 the Supreme Court stated:The purpose of the exclusionary rule is not to redress the injury to the privacy of the search victim....Instead, the rule's prime purpose is to deter future unlawful police conduct and thereby effectuate the guarantee of the Fourth Amendment against unreasonable search and seizures: 'The rule is calculated to prevent, not to repair.'...In sum, the rule is a judicially created remedy designed to safeguard Fourth Amendment rights generally through its deterrent effect, rather than a personal constitutional right of the party aggrieved.12Although the exclusionary rule most often is applied to violations of the Fourth Amendment, it has been applied to other constitutional violations as well.13The Supreme Court consistently has recognized that the inflexible application of the exclusionary rule would generate disrespect for the law and impede the administration of justice.14 With that in mind, and because the exclusionary rule is not considered a constitutionally required remedy, courts have carved out a number of exceptions and limitations to the rule, where to otherwise apply the rule would go beyond the limited goal of simply deterring illegal police conduct.15 For instance, most courts will not suppress evidence found during an illegal search when the evidence is also locat...
