	Introduction

Willie Davis was a passenger in a car stopped by police in Greenville, Alabama, for a traffic violation. The police arrested Davis for giving a false name. After handcuffing him and placing him in the back of a patrol car, the police searched the passenger compartment of the car in which Davis had been riding. The police found a gun inside Davis's jacket, and Davis was convicted of possessing a firearm as a convicted felon. At the time of the search, the police were acting in conformity with Eleventh Circuit precedent. After Davis was convicted, however, the Supreme Court held in Arizona v. Gant that this type of suspicionless vehicle search incident to arrest violated the Fourth Amendment to the U.S. Constitution. Instead, the Supreme Court has described the rule as a pragmatic doctrine that only applies when the benefits of evidentiary suppression exceed its costs to the justice system. The Exclusionary Rule and Its Good-Faith Exception

Courts apply the exclusionary rule to deter Fourth Amendment violations by suppressing unconstitutionally seized evidence. Arguably the good-faith exception is the most significant exception to the exclusionary rule. It permits the unconstitutionally obtained evidence to be introduced at trial when it was seized in "good-faith" by law enforcement officers. However, the Court wrote that "the flagrancy of the police misconduct" has always "constituted an important step in the calculus" of the exclusionary rule, and it characterized the exclusionary rule's evolution as a series of cases excluding evidence obtained as a result of flagrant or deliberate violations of suspects' rights. The case confirms that, under the Herring test, police culpability is now the sole relevant factor in determining whether the exclusionary rule applies. United States v. Davis

		Opinion of the Court

In United States v. Davis , Davis contended that police culpability was only one relevant factor in determining whether the exclusionary rule applies. He contended that the exclusionary rule can also apply for other reasons, including (1) if doing so is constitutionally mandated under the retroactivity doctrine, which requires courts to apply recently announced Fourth and Fifth Amendment rules retroactively to certain cases on direct review, and (2) if its application would facilitate the development of Fourth Amendment law by incentivizing future appeals. One Justice concurred in the judgment and two dissented. Moreover, unlike the Eleventh Circuit, she rejected the view that an officer's culpability is dispositive of the exclusionary rule's applicability. Implications for Congressional Action

Congress has occasionally considered supplementing the Supreme Court's exclusionary rule jurisprudence with legislation codifying the exclusionary rule or the good-faith exception. It is therefore widely accepted that Congress has broad authority to bar (or require) the exclusionary rule in federal cases, and the Court's opinion in Davis supports this position. Conclusion

Davis v. United States was the first case in which the Supreme Court applied the "deliberate" and "culpable" Herring standard for the good-faith exception's application. The Supreme Court held that evidence seized in an unconstitutional search that, at the time it was conducted, complied with precedent is admissible because police do not act culpably when they conform with "binding appellate precedent."
In Davis v. United States, the Supreme Court held that evidence seized in violation of the defendant's Fourth Amendment rights is admissible at trial when the police seized the evidence in good-faith reliance on "binding appellate precedent." The petitioner in that case, Willie Davis, was a passenger in a car that was stopped by police for a traffic violation. The police arrested the driver for driving while intoxicated and Davis for giving a false name. After handcuffing Davis and placing him in the back of a patrol car, the police searched the passenger compartment of the car in which Davis had been riding. The police found a revolver inside Davis's jacket, and Davis was convicted of possessing a firearm as a convicted felon.
At the time of the search, the police were acting in conformity with controlling Eleventh Circuit precedent. However, after Davis was convicted and had filed an appeal, the Supreme Court ruled that this type of vehicle search incident to arrest was unconstitutional under the Fourth Amendment. Nevertheless, when Davis's appeal reached the Court, it held that even though the search was unconstitutional, the gun it produced was admissible under the good-faith exception to the exclusionary rule.
The exclusionary rule bars evidence obtained in an unconstitutional search from being introduced at trial. The rule is a pragmatic doctrine intended to deter Fourth Amendment violations. It traditionally applies when (1) no exception, such as the good-faith exception, bars its operability; (2) exclusion will achieve "appreciable deterrence" of Fourth Amendment violations; and (3) the benefits of evidentiary suppression outweigh its burdens on the justice system.
In 2009, the Supreme Court broadened the good-faith exception when it announced in Herring v. United States that unconstitutionally obtained evidence is admissible at trial unless the evidence was the product of "deliberate" and "culpable" police misconduct. Davis was the first Supreme Court case to apply the Herring standard. The case furthers the impression that police culpability is now the sole relevant factor in determining whether the exclusionary rule applies. The Court rejected Davis's contentions that other relevant factors include whether the exclusionary rule's application would facilitate the development of Fourth Amendment law and whether a recently announced Fourth and Fifth Amendment rule applies retroactively. Two Justices dissented from the Court's opinion. One Justice concurred in the judgment but rejected the Court's view that police culpability is the dispositive factor in an assessment of whether the exclusionary rule applies.
Congress has occasionally considered legislation codifying the exclusionary rule or its good-faith exception. The scope of Congress's authority to enact or modify exclusionary rule jurisprudence depends on the extent to which the exclusionary rule is constitutionally required. The Supreme Court in Davis emphasized that the exclusionary rule's application is not constitutionally mandated by either the Fourth Amendment or the retroactivity doctrine. Accordingly, Davis supports the view that Congress has substantial authority to mandate the exclusionary rule's applicability or inapplicability in federal court cases.