Does the exclusionary rule of evidence apply to searches conducted solely by foreign officials?

In Stonehill v. United States, 405 F.2d 738, 743 (9th Cir.1968), cert. denied, 395 U.S. 960, 89 S.Ct. 2102, 23 L.Ed.2d 747 (1969), we observed that "[n]either the Fourth Amendment to the United States Constitution nor the exclusionary rule of evidence, designed to deter Federal officers from violating the Fourth Amendment, is applicable to the acts of foreign officials." Id. at 743. Because the fourth amendment does not itself require exclusion of unlawfully obtained evidence, and because excluding reliable evidence will not force foreign officers to abide by the norms of the fourth amendment, the exclusionary rule has no application to searches conducted solely by a foreign government. Id. We explained, however, that "the Fourth Amendment could apply to raids by foreign officials ... if Federal agents so substantially participated in the raids so as to convert them into joint ventures between

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