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The origins of the exclusionary rule can be traced back to. the 1886 case of Boyd v. United States, in which the Supreme. Court held that demanding private papers from a defendant to. use against him at trial was an invasion of the indefeasible. right of personal security, personal liberty and private prop-.
A companion to the exclusionary rule is the fruit of the poisonous tree doctrine. Under this doctrine, a court may exclude from trial not only evidence that itself was seized in violation of the Constitution but also any other evidence that is derived from an illegal search.or the more than 100 years after its ratification, the Fourth Amendment was of little value to criminal defendants because evidence seized by law enforcement in violation of the warrant or reasonableness requirements was still admissible during the defendant's prosecution.