Herring v. United States

E545159

United States Supreme Court case criminal procedure case

Herring v. United States is a 2009 U.S. Supreme Court case that further limited the application of the exclusionary rule by holding that evidence need not be suppressed when obtained through isolated police negligence rather than deliberate or reckless misconduct.

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All labels observed (1)

Label	Occurrences
Herring v. United States canonical	3

How this entity was disambiguated

This entity first appeared as the object of triple T5770516 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Herring v. United States
Context triple: [United States v. Leon, subsequentCitationBy, Herring v. United States]

A. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
B. Dorr v. United States
Dorr v. United States is a 1904 U.S. Supreme Court decision that helped define the limited application of constitutional rights in unincorporated territories under the Insular Cases doctrine.
C. Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
D. Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
E. Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Herring v. United States
Target entity description: Herring v. United States is a 2009 U.S. Supreme Court case that further limited the application of the exclusionary rule by holding that evidence need not be suppressed when obtained through isolated police negligence rather than deliberate or reckless misconduct.

A. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
B. Dorr v. United States
Dorr v. United States is a 1904 U.S. Supreme Court decision that helped define the limited application of constitutional rights in unincorporated territories under the Insular Cases doctrine.
C. Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
D. Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
E. Yates v. United States
Yates v. United States is a 1957 U.S. Supreme Court decision that significantly narrowed the application of the Smith Act by distinguishing between the advocacy of abstract doctrine and the advocacy of concrete action to overthrow the government.
F. None of above. chosen

Statements (45)

Predicate	Object
instanceOf	United States Supreme Court case ⓘ criminal procedure case ⓘ
category	United States Supreme Court cases decided in 2009 ⓘ United States Supreme Court cases on the Fourth Amendment ⓘ
citation	129 S. Ct. 695 ⓘ 172 L. Ed. 2d 496 ⓘ 555 U.S. 135 ⓘ
clarifies	Arizona v. Evans ⓘ United States v. Leon ⓘ
constitutionalProvisionInterpreted	Fourth Amendment to the United States Constitution ⓘ
court	Supreme Court of the United States ⓘ
decisionDate	2009-01-14 ⓘ
dissentingOpinionBy	Justice Ruth Bader Ginsburg ⓘ linked to: Ruth Bader Ginsburg
doctrine	good-faith exception to the exclusionary rule ⓘ
holding	Evidence obtained as a result of isolated police negligence not sufficiently deliberate or culpable does not require suppression under the exclusionary rule. ⓘ Negligent bookkeeping error by police personnel does not trigger exclusion when not part of systemic error or reckless disregard of constitutional requirements. ⓘ The exclusionary rule applies only where its deterrent benefits outweigh its substantial social costs. ⓘ
impact	expanded the good-faith exception to include certain negligent police recordkeeping errors ⓘ narrowed application of the exclusionary rule ⓘ
joinedByInDissent	Justice David H. Souter ⓘ linked to: David H. Souter Justice John Paul Stevens ⓘ linked to: John Paul Stevens Justice Stephen G. Breyer ⓘ linked to: Stephen G. Breyer
joinedByInMajority	Justice Anthony M. Kennedy ⓘ linked to: Anthony M. Kennedy Justice Antonin Scalia ⓘ linked to: Antonin Scalia Justice Clarence Thomas ⓘ linked to: Clarence Thomas Justice Samuel A. Alito, Jr. ⓘ linked to: Samuel A. Alito Jr.
jurisdiction	United States ⓘ linked to: United States of America
keyPrinciple	Exclusion is a last resort, not a first impulse. ⓘ
legalIssue	Fourth Amendment search and seizure ⓘ scope of the exclusionary rule ⓘ
majorityOpinionBy	Chief Justice John G. Roberts, Jr. ⓘ linked to: John G. Roberts Jr.
originatingState	Alabama ⓘ
petitioner	Bennie Dean Herring ⓘ
proceduralPosture	certiorari to the United States Court of Appeals for the Eleventh Circuit ⓘ
relatedCase	Arizona v. Evans ⓘ Hudson v. Michigan ⓘ Mapp v. Ohio ⓘ United States v. Leon ⓘ
respondent	United States ⓘ linked to: United States of America
result	Judgment of the Eleventh Circuit affirmed ⓘ
standardAnnounced	Exclusionary rule applies when police conduct is deliberate, reckless, grossly negligent, or involves recurring or systemic negligence. ⓘ
subjectMatter	criminal evidence suppression ⓘ police negligence ⓘ
term	October Term 2008 ⓘ
votingSplit	5-4 decision ⓘ