The Fact That Federal Courts Have Relied on a Discretionary

The fact that federal courts have relied on a discretionary use of the exclusionary rule in recent years means that

A) states are no longer required to provide legal counsel to people accused of a crime.
B) states no longer have to follow the Miranda rule.
C) it is difficult to know whether a defendant will or will not be protected from an illegal search under the Fourth Amendment.
D) defendants will never be protected from an illegal search under the Fourth Amendment.
E) defendants will always be protected from an illegal search under the Fourth Amendment.