employees on similar grounds. [ 127 ] Searches of prison cells are subject to no restraints relating to reasonableness or probable cause. [ 128 ] Exclusionary rule One way courts enforce the Fourth Amendment is through the use of the exclusionary rule. The rule provides that evidence obtained through a violation of the Fourth Amendment is generally not admissible by the prosecution during the defendant's criminal trial. [ 129 ] The Court stated in Elkins v. United States (1960) [ 130 ] that the rule's function "is to deter—to compel respect for the constitutional guaranty in the only effectively available way—by removing the incentive to disregard it." [ 129 ] The exclusionary rule and its effectiveness have often been controversial, particularly since its 1961 application to state proceedings. Critics charge that the rule hampers police investigation and can result in freeing guilty parties convicted on reliable evidence; other critics state that the rule has not been successful in deterring illegal police searches. Proponents argue that the number of criminal convictions overturned under the rule has been minimal and that no other effective mechanism exists to enforce the Fourth Amendment. [ 129 ] In 1982, California passed a " Victim's Bill of Rights " containing a provision to repeal the exclusionary rule; though the bill could not affect federally mandated rights under the Fourth Amendment, it blocked the state courts from expanding these protections further. [ 137 ] [ 138 ] Limitations Responding to criticisms of the exclusionary rule, the Supreme