Leon good-faith exception (Kansas) · Go Syfert
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Leon good-faith exception in Kansas

19 Kansas opinions name it 2 courts 2004–2026 3 in the last five years

The cases below were cited by Kansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
United States v. Leongreen
scotus · 1984 · cited in 5 Kansas opinions naming this issue, 2007–2025
2 sentences

2025To do so, 'we look to the affidavit in its entirety' and determine '"whether a reasonably well trained officer would have known that the search was illegal despite the magistrate's authorization."' Powell, 299 Kan. at 701 (quoting Leon, 468 U.S. at 922 n.23).

2020Because this weighing is fact-specific, "suppression of evidence . . . should be ordered only on a case-by-case basis and only in those unusual cases in which exclusion will further the purposes of the exclusionary rule." Leon, 468 U.S. at 918 . 7 In Krull, the United States Supreme Court expanded the Leon good-faith exception to include an officer's reasonable reliance on an unconstitutional statute. 480 U.S. at 349 - 50.

25
State v. Doilegreen
kan · 1989 · cited in 4 Kansas opinions naming this issue, 2004–2020
2 sentences

2007The court went on to hold that the search could not be saved by the Leon good faith exception. 244 Kan. at 502-03 , 769 P.2d 666 .

2007The court went on to hold that the search could not be saved by the Leon good faith exception. 244 Kan. at 502-03 , 769 P.2d 666 .

14
State v. Hicksgreen
kan · 2006 · cited in 3 Kansas opinions naming this issue, 2007–2020
2 sentences

2008See Hicks, 282 Kan. at 617-18 , 147 P.3d 1076 (where State failed to pursue argument under Leon , our Supreme Court regarded argument as waived); see also State v. Landis, 37 Kan.App.2d 409, 423 , 156 P.3d 675 , rev. denied 284 Kan. 949 (2007) (holding that the State's failure to make an argument regarding the application of the Leon good-faith exception on appeal is deemed waived).

2008See Hicks, 282 Kan. at 617-18 , 147 P.3d 1076 (where State failed to pursue argument under Leon , our Supreme Court regarded argument as waived); see also State v. Landis, 37 Kan.App.2d 409, 423 , 156 P.3d 675 , rev. denied 284 Kan. 949 (2007) (holding that the State's failure to make an argument regarding the application of the Leon good-faith exception on appeal is deemed waived).

13
State v. Danielgreen
kan · 2010 · cited in 3 Kansas opinions naming this issue, 2013–2020
2 sentences

2020The Kansas Supreme Court adopted Krull's expansion of the Leon good-faith exception to excuse a police officer's reasonable reliance on a statute in State v. Daniel, 291 Kan. 490, 500 , 242 P.3d 1186 (2010).

2020The Kansas Supreme Court adopted Krull's expansion of the Leon good-faith exception to excuse a police officer's reasonable reliance on a statute in State v. Daniel, 291 Kan. 490, 500 , 242 P.3d 1186 (2010).

13
State v. Hoeckgreen
kan · 2007 · cited in 2 Kansas opinions naming this issue, 2008–2014
2 sentences

2008In Hoeck , however, our Supreme Court recently disapproved of this test and held: "The Leon good faith exception applies when an affidavit does not supply a substantial basis for the determination of probable cause but does provide some indicia of probable cause sufficient to render official reliance reasonable." 284 Kan. 441 , Syl. ¶ 2, 163 P.3d 252 .

2008In Hoeck , however, our Supreme Court recently disapproved of this test and held: "The Leon good faith exception applies when an affidavit does not supply a substantial basis for the determination of probable cause but does provide some indicia of probable cause sufficient to render official reliance reasonable." 284 Kan. 441 , Syl. ¶ 2, 163 P.3d 252 .

12
State v. Landisgreen
kanctapp · 2007 · cited in 1 Kansas opinions naming this issue, 2008–2008
2 sentences

2008See Hicks, 282 Kan. at 617-18 , 147 P.3d 1076 (where State failed to pursue argument under Leon , our Supreme Court regarded argument as waived); see also State v. Landis, 37 Kan.App.2d 409, 423 , 156 P.3d 675 , rev. denied 284 Kan. 949 (2007) (holding that the State's failure to make an argument regarding the application of the Leon good-faith exception on appeal is deemed waived).

2008See Hicks, 282 Kan. at 617-18 , 147 P.3d 1076 (where State failed to pursue argument under Leon , our Supreme Court regarded argument as waived); see also State v. Landis, 37 Kan.App.2d 409, 423 , 156 P.3d 675 , rev. denied 284 Kan. 949 (2007) (holding that the State's failure to make an argument regarding the application of the Leon good-faith exception on appeal is deemed waived).

11
Atkins v. Parkergreen
scotus · 1984 · cited in 1 Kansas opinions naming this issue, 2008–2008
1 sentence

2008See United States v. Leon, 468 U.S. 897 , 104 S.Ct. 3430 , 82 L.Ed.2d 677 , reh. denied 468 U.S. 1250 , 105 S.Ct. 52 , 82 L.Ed.2d 942 (1984).

11
South Street Seaport Museum v. McCarthygreen
scotus · 1984 · cited in 1 Kansas opinions naming this issue, 2008–2008
1 sentence

2008See United States v. Leon, 468 U.S. 897 , 104 S.Ct. 3430 , 82 L.Ed.2d 677 , reh. denied 468 U.S. 1250 , 105 S.Ct. 52 , 82 L.Ed.2d 942 (1984).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
State v. Powell green
kan · 2014
2 sentences

2026We are mindful that "[t]he threshold to avoid the Leon good-faith exception is a high one." State v. Powell, 299 Kan. 690, 701 , 325 P.3d 1162 (2014).

2026We are mindful that "[t]he threshold to avoid the Leon good-faith exception is a high one." State v. Powell, 299 Kan. 690, 701 , 325 P.3d 1162 (2014).

42020–2026
Illinois v. Krull green
scotus · 1987
2 sentences

2020Because this weighing is fact-specific, "suppression of evidence . . . should be ordered only on a case-by-case basis and only in those unusual cases in which exclusion will further the purposes of the exclusionary rule." Leon, 468 U.S. at 918 . 7 In Krull, the United States Supreme Court expanded the Leon good-faith exception to include an officer's reasonable reliance on an unconstitutional statute. 480 U.S. at 349 - 50.

2020Illinois v. Krull, 480 U.S. 340, 349-50 , 107 S. Ct. 1160 , 94 L.

32019–2020
State v. Malm green
kanctapp · 2007
2 sentences

2025State v. Malm, 37 Kan.

2007App. 2d 532, 548 , 154 P.3d 1154 (2007) (“The court’s rea *462 sorting in Doile is somewhat curious because the Leon good faith exception is only triggered in cases where a court subsequently determines that the search warrant affidavit fails to establish a substantial basis for probable cause.

22007–2025
Horton v. California green
scotus · 1990
2 sentences

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

22007–2020
State v. Ratzlaff green
kan · 1994
2 sentences

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

22007–2020
State v. Longbine green
kan · 1995
2 sentences

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

2020We disapprove any language in State v. Longbine, 257 Kan. 713, 721-22 , 896 P.2d 367 (1995), disapproved on other grounds by State v. Hicks, 282 Kan. 599 , 147 P.3d 1076 (2006), State v. Ratzlaff, 255 Kan. 738, 754-55 , 877 P.2d 397 (1994), and State v. Doile, 244 Kan. 493, 495 , 769 P.2d 666 (1989), abrogated on other grounds by Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.

22007–2020
State v. Potts green
kan · 2016
2 sentences

2024State v. Potts, 304 Kan. 687, 700 , 374 P.3d 639 (2016). 12 Verser argues his trial counsel did not make a specific and contemporaneous objection on day four of the trial that would have preserved the issue on whether the Leon good-faith exception to the exclusionary rule applied despite the lack of probable cause in the search warrant.

2024State v. Potts, 304 Kan. 687, 700 , 374 P.3d 639 (2016). 12 Verser argues his trial counsel did not make a specific and contemporaneous objection on day four of the trial that would have preserved the issue on whether the Leon good-faith exception to the exclusionary rule applied despite the lack of probable cause in the search warrant.

12024–2024
Groh v. Ramirez green
scotus · 2004
2 sentences

2016The Groh court indirectly provided guidance on how to apply that exception to the facts of this case, although Groh was a civil action for damages caused by the illegal search as opposed to a criminal action like the one we now consider In Groh v. Ramirez, 540 U.S. 551 , 124 S. Ct. 1284 , 157 L.

2016The Groh court indirectly provided guidance on how to apply that exception to the facts of this case, although Groh was a civil action for damages caused by the illegal search as opposed to a criminal action like the one we now consider In Groh v. Ramirez, 540 U.S. 551 , 124 S. Ct. 1284 , 157 L.

12016–2016
Messerschmidt v. Millender green
scotus · 2012
2 sentences

2014For this, the question is not whether the judge erred in believing there was sufficient probable cause to issue the warrant, the inquiry instead is whether that judge “so obviously erred that any reasonable officer would have recognized the error.” Messerschmidt v. Millender, 565 U.S. _ , 132 S. Ct. 1235, 1250 , 182 L.

2014For this, the question is not whether the judge erred in believing there was sufficient probable cause to issue the warrant, the inquiry instead is whether that judge “so obviously erred that any reasonable officer would have recognized the error.” Messerschmidt v. Millender, 565 U.S. _ , 132 S. Ct. 1235, 1250 , 182 L.

12014–2014
State v. Hemme green
kanctapp · 1991
2 sentences

2007This is why we have the Leon good faith exception in the first place.”); State v. Hemme, 15 Kan.

2007This is why we have the Leon good faith exception in the first place.”); State v. Hemme, 15 Kan.

12007–2007
State v. Jackson green
kanctapp · 2002
1 sentence

2007In State v. Jackson, 30 Kan.

12007–2007
State v. Probst green
kan · 1990
2 sentences

2007Under the Leon good faith exception, evidence should not be excluded unless it is shown: “ ‘(1) that the judge or magistrate who issued the warrant was deliberately misled by false information; (2) that the judge or magistrate wholly abandoned his or her neutral and detached role; (3) that the warrant was so lacking in specificity that die officers could not determine the place to be searched or the things to be seized; or (4) that there was so little indicia of probable cause contained in the warrant that it was entirely unreasonable for an officer to believe the warrant valid. [Citation omit

2007Under the Leon good faith exception, evidence should not be excluded unless it is shown: “ ‘(1) that the judge or magistrate who issued the warrant was deliberately misled by false information; (2) that the judge or magistrate wholly abandoned his or her neutral and detached role; (3) that the warrant was so lacking in specificity that die officers could not determine the place to be searched or the things to be seized; or (4) that there was so little indicia of probable cause contained in the warrant that it was entirely unreasonable for an officer to believe the warrant valid. [Citation omit

12007–2007
Burche v. Degussa Carbon Black Co. green
scotus · 1991
1 sentence

2007App. 2d 198, 204 , 806 P.2d 472 , rev. denied 248 Kan. 998 , cert. denied 502 U.S. 865 (1991) (noting that the Doile court added a probable cause requirement to Leon’s good faith exception by quoting “some preliminary probable cause language from earlier in the Leon opinion”).

12007–2007
State v. Hendricks green
kanctapp · 2003
1 sentence

2007Leon, 468 U.S. at 916 .” State v. Hendricks, 31 Kan.

12007–2007

Statutes the citing opinions construe

KS § K.S.A. § 60-1507 (4) KS § K.S.A. § 22-2502 (3) KS § K.S.A. § 8-1025 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 30 (1994–2021) KS 19 (2004–2026) VA 16 (1993–2024) CA 13 (1988–2023) MD 12 (1992–2023) AR 11 (1991–2012) LA 7 (1985–2018) IN 7 (1997–2009) GA 7 (1992–2024) NE 7 (1996–2019) ID 6 (1989–2012) TX 5 (1987–2017) MN 4 (1987–2025) DC 4 (1992–2017) WI 4 (1991–2022) CO 3 (1993–1999) ND 3 (1988–2015) NC 3 (1988–2021) IA 3 (2000–2017) TN 2 (2016–2016) PA 2 (1987–2014) OH 2 (1999–2014) KY 2 (2010–2023) SC 2 (2006–2006) FL 2 (1989–2008) MS 2 (2011–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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