Supreme Court Case: California V. Greenwood

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Identify the case:
The case California v. Greenwood can be found in volume 486 of the United States Supreme Court Reporter, page 35. The case was argued January 11, 1988 and decided on May 16, 1988.

Background information:
In February of 1984, a Drug Enforcement Administration (DEA) agent informed Jenny Stracner, an investigator for the Laguna Beach Police Department, that a U-Haul truck full of illegal drugs was en route to Greenwood’s address. In addition to this information, Greenwood’s neighbor complained of heavy vehicular traffic late at night in front of the Greenwood’s home. The neighbor noted that the visitors would only stay for a few minutes and that a U-Haul had been parked in front of the house for four days. With this, Stracner
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Reasoning process:
The Exclusionary rule of the Fourteenth Amendment states that evidence gathered by violating the Fourth, Fifth, and Sixth Amendments cannot be used in trial. Since California eliminated this rule, Greenwood believed this violated his rights. However, the Court found no merit in his position because at the federal level, evidence obtained in violation of the Fourth Amendment does not have to be withheld in all circumstances. When law enforcement officers are acting in good faith or their misbehavior is minor, the evidence they collected can be used.
The main issue in this case was if warrantless searches and seizures of garbage left for collection outside of the home violates the Fourth Amendment. The case, People v. Krivda, created a California state law that forbids warrantless searches of trash. Due to this state law, charges against Greenwood in the California courts were dismissed because finding probable cause to obtain a search warrant would not have been possible, had the evidence from the trash not been obtained. However, in Federal Court, this state law does not apply.

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