THE HISTORY AND SHORTCOMINGS OF THE EXCLUSIONARY RULE AS A MEANS OF DEALING WITH UNLAWFUL POLICE SEARCHES ARE REVIEWED. THE POLICY ADVANTAGES OF JUDICIALLY REQUIRED RULEMAKING BY LAW ENFORCEMENT AGENCIES ARE OUTLINED, AND A PROPOSAL FOR INTRODUCING SUCH A RULEMAKING REQUIREMENT IS ARTICULATED. METHODS OF IMPLEMENTING THE PROPOSAL--CONGRESSIONAL MANDATE, REMEDIAL POWER IMPLIED FROM THE FOURTH AMENDMENT, SUPERVISORY POWER OF FEDERAL COURTS -- ARE CONSIDERED, WITH EMPHASIS ON THE FEDERAL COURTS' SUPERVISORY POWER TO PRESCRIBE RULES FOR LAW ENFORCEMENT AND TO EXCLUDE ILLEGALLY SEIZED EVIDENCE. UNDER THE PROPOSAL, A COURT THAT FINDS A FOURTH AMENDMENT VIOLATION CAN REQUIRE THE CULPABLE LAW ENFORCEMENT AGENCY TO DEVELOP GUIDELINES AIMED AT AVOIDING REPETITIONS OF THE VIOLATION. POLICE INVOLVEMENT IN ESTABLISHING, ADMINISTERING, AND MONITORING SEARCH-AND-SEIZURE GUIDELINES HAS THE POTENTIAL TO DETER VIOLATIONS OF CONSTITUTIONAL RIGHTS AND TO IMPROVE BOTH POLICE-COURT RELATIONS AND THE QUALITY OF LAW ENFORCEMENT. A LEGISLATIVE INITIATIVE PROVIDING THE COURTS WITH REMEDIAL POWER TO ORDER RULEMAKING WOULD BE IDEAL IN THAT IT WOULD PRESERVE THE MORE TRADITIONAL ROLES OF THE LEGISLATURE AND THE COURTS. BUT IN THE ABSENCE OF CONGRESSIONAL ACTION, IMPOSITION OF A RULEMAKING REQUIREMENT AS A SANCTION AGAINST FOURTH AMENDMENT VIOLATIONS IS AN APPROPRIATE EXERCISE OF THE FEDERAL COURTS' SUPERVISORY POWER. (LKM)