would have been reduced to a form of words,” id. at 648, 81 S.Ct. 1684 (internal quotation marks and citations omitted), and, accordingly, held that “all evidence obtained by searches and seizures in violation of the Constitution is, by the same authority, inadmissible in a state court.” Id. at 655, 81 S.Ct. 1684. More recently, however, the Court has relied on the rule’s deterrent purpose in declining to expand its application beyond traditional criminal proceedings. See, e.g., 1.N.S. v. Lopez-Mendoza, 468 U.S. 1032, 1043, 104 S.Ct. 3479, 82 L.Ed.2d 778 (1976) (refusing to employ the exclusionary rule in deportation proceedings in part because the “deterrent value” of the rule would not be served); United States v. Calandra, 414 U.S. 338, 351, 94 S.Ct. 613, 38 L.Ed.2d 561 (1974) (<HOLDING>). Indeed, even within the context of criminal
holding that right was available in grand jury proceedings holding no right to crossexamine in grand jury proceedings holding that grand jury witnesses may not refuse to answer questions on the ground that they are based on illegally seized evidence because any incremental deterrent effect which might be achieved by extending the rule to grand jury proceedings is uncertain at best holding the trial court erred in ordering the transcription of grand jury proceedings so that it could intervene in the operations of the grand jury holding that the government is not required to present exculpatory evidence to the grand jury