TY  - JOUR
AB  - The exclusionary rule remains one of the most controversial doctrines in America’s constitutionalized criminal procedure. Jurists and commentators criticize the American exclusionary rule as a rule unique to American jurisprudence. Though American jurists and commentators’ criticism focuses on the Fourth Amendment exclusionary rule, the criticism of the American exclusionary rule with reference to practices in foreign countries serves to create and maintain the misconception that the United States is the only country that has the exclusionary rule. The belief that the exclusionary rule exists only in the United States is far from accurate. This article examines the historical development and the current status of exclusionary rules in the United States, England, France, Germany, and Italy. Attentions are especially devoted to analyzing the characteristics of the American exclusionary rule with reference to exclusionary rules in other countries.
VL  - 22
IS  - 3
SN  - 1363-951X
DO  - 10.1108/13639519910285053
UR  - https://doi.org/10.1108/13639519910285053
AU  - Ma Yue
PY  - 1999
Y1  - 1999/01/01
TI  - Comparative analysis of exclusionary rules in the United States, England, France, Germany, and Italy
T2  - Policing: An International Journal of Police Strategies & Management
PB  - MCB UP Ltd
SP  - 280
EP  - 303
Y2  - 2024/04/25
ER  -