court. In Silverthorne Lumber Co. v. United States (1920) and Nardone v. United States (1939), the Court ruled that leads or other evidence resulting from illegally obtained evidence are also inadmissible in trials. Justice Felix Frankfurter described this secondary evidence in the Nardone decision as the "fruit of the poisonous tree". The Supreme Court rejected incorporating the exclusionary rule by way of the Fourteenth Amendment in Wolf v. Colorado (1949), but Wolf was explicitly overruled in Mapp v. Ohio (1961), making the Fourth Amendment (including the exclusionary rule) applicable in state proceedings. The exclusionary rule and its effectiveness have often been controversial, particularly since its 1961 application to state proceedings. Critics charge that the rule hampers police investigation and can result in freeing guilty parties convicted on reliable evidence; other critics say the rule has not been successful in deterring illegal police searches. Proponents argue that the number of criminal convictions overturned under the rule has been minimal and that no other effective mechanism exists to enforce the Fourth Amendment. In 1982, California passed a "Victim's Bill of Rights" containing a provision to repeal the exclusionary rule; though the bill could not affect federally mandated rights under the Fourth Amendment, it blocked the state courts from expanding these protections further. Limitations Since 1974, the Supreme Court has repeatedly limited the exclusionary rule. In United States v. Calandra (1974), the Court ruled that grand juries may use illegally obtained evidence when questioning witnesses, because "the damage to that institution from the unprecedented extension of the exclusionary rule outweighs the benefit of any possible incremental deterrent effect." Explaining the purpose of the rule, the Court said 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." Three cases in 1984 further restricted the exclusionary rule: In United States v. Leon (1984), the Court established the "good faith" exception to the rule, ruling that evidence seized by officers reasonably relying on a warrant was still admissible, even though the warrant was later found to be defective, unless an officer dishonestly or recklessly prepared an affidavit to seek a warrant, the issuing magistrate abandoned his neutrality, or the warrant lacked sufficient particularity. The Court determined in Nix v. Williams (1984) that "fruit of the poisonous tree" evidence could still be introduced if a prosecutor could demonstrate