Does the good faith exception apply to negligent conduct by law enforcement officials such as conducting a search when the officials in question should have known a search was unconstitutional?

Before Herring, supra, 555 U.S. 135, the good faith exception did not apply to negligent conduct by law enforcement officials, such as conducting a search when the officials in question should have known a search was unconstitutional. (See, e.g., People v. Willis, supra, 28 Cal.4th at p. 48.) After Herring, the good faith exception remains applicable "when police mistakes are the result of negligence . . . rather than systemic error or reckless disregard of constitutional requirements." (Herring, at p. 147.) In other words, if the error made by the officer was merely negligent, the extreme sanction of suppression is not appropriate. However, the exclusionary rule continues to serve "to deter deliberate, reckless, or grossly negligent [law enforcement] conduct, or in some circumstances recurring or systemic negligence." (Id. at p. 144.)