Does the exclusionary rule apply to residential searches?

Finally, we observe the principal purpose of the exclusionary rule "`is to deter future unlawful police conduct and thereby effectuate the guarantee of the Fourth Amendment against unreasonable searches and seizures.'" (Illinois v. Krull (1987) 480 U.S. 340, 347, 107 S.Ct. 1160, 94 L.Ed.2d 364, quoting United States v. Calandra (1974) 414 U.S. 338, 347, 94 S.Ct. 613, 38 L.Ed.2d 561.) In Tyrell J., we concluded that dispensing with a strict "knowledge-first" rule would not encourage law enforcement officials to engage in warrantless searches of juveniles because they would be "[taking] the chance" that if the target of a search is not subject to a search condition, any contraband found will be inadmissible in court. (Tyrell J., supra, 8 Cal.4th at p. 89, 32 Cal.Rptr.2d

[97 Cal.Rptr.2d 922]

33, 876 P.2d 519.) Although police officers therefore have sufficient incentive to avoid an improper search of a person (ibid.), residential searches present an altogether different situation.

[97 Cal.Rptr.2d 922]