<P> In the case of Florida v. Jimeno it was found that the evidence found to convict Jimeno, although at first was not admissible, later was found to in fact be admissible since it passed the test of reasonable standards . The defendant consented to a search of his car, and when the officer searched a package and found drugs, it was not said to be in violation because a reasonable person would expect illegal narcotics to be kept in a package or container . </P> <P> The Special Operations Division of the U.S. Drug Enforcement Administration advises DEA agents to follow a process of parallel construction when launching criminal investigations of Americans based on SOD tips that may be based on warrantless surveillance . </P> <P> The exclusionary rule as it has developed in the United States has been long criticized . Judge Benjamin Cardozo, Chief Judge of the New York Court of Appeals between 1927 and 1932, stated that under the rule, "The criminal is to go free because the constable has blundered ." The judge noted that many states had rejected the rule, but suggested that the adoption by the federal courts would affect the practice in the sovereign states . </P> <P> In the 1970s, Dallin H. Oaks, Malcolm Wilkey, and others called for the exclusionary rule to be replaced with a comprehensive judicial remedy against all illegal arrests and searches and seizures (e.g., tort remedy). By the 1980s, the exclusionary rule remained controversial and was strongly opposed by President Ronald Reagan . But, some opponents began seeking to have the rule modified, rather than abolished altogether . The case, Illinois v. Gates, before the Supreme Court brought the exclusionary rule for reconsideration . The Supreme Court also considered allowing exceptions for errors made by police in good faith . The Reagan administration also asked Congress to ease the rule . It has been proposed that the exclusionary rule be replaced with restitution to victims of police misconduct . </P>

How has the supreme court modified the exclusionary rule