Weeks v. United States
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| Weeks v. United States | |||||||||||
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| Argued December 2 – 3, 1913 Decided February 24, 1914 |
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| Holding | |||||||||||
| The warrantless seizure of documents from a private home violated the Fourth Amendment prohibition against unreasonable searches and seizures, and evidence obtained in this manner is excluded from use in federal criminal prosecutions. Western District of Missouri reversed and remanded. | |||||||||||
| Court membership | |||||||||||
| Chief Justice: Edward Douglass White Associate Justices: Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, Horace Harmon Lurton, Charles Evans Hughes, Willis Van Devanter, Joseph Rucker Lamar, Mahlon Pitney |
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| Case opinions | |||||||||||
| Majority by: Day Joined by: unanimous |
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| Laws applied | |||||||||||
| U.S. Const. amend. IV | |||||||||||
Weeks v. United States, 232 U.S. 383 (1914), is a case in which the United States Supreme Court held unanimously that illegal seizure of items from a private residence constitutes a violation of the Fourth Amendment.1 It also set forth the exclusionary rule that prohibits admission of illegally obtained evidence in federal courts.2
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[edit] Background of the case
[edit] Use of illegally obtained evidence
The rules and procedure governing use of evidence in the American judicial system arises largely from the English common law, and until 1914, the United States Supreme Court remained faithful to the precepts it dictated – that is, that the process by which evidence was obtained had very little to do with the permissibility of its use in court. Common law stated that the evidence may be used, and that there could be legal prosecution and punishment of those guilty of breaking the law in order to obtain the evidence.
In several earlier cases, the U.S. Supreme Court abided by these common law rules, and allowed both state and federal courts to employ evidence obtained by an illegal search and seizure. However, in the late 19th and early 20th century, this attitude began to shift, as arguments were made that if the Court did not recognize that the Fourth Amendment provides protection against unlawful searches, the amendment itself would be meaningless.
In the landmark case of Weeks v. United States (1914), the Court ruled for the first time (and did so unanimously) that the Fourth Amendment provides protection against “unreasonable searches and seizures” in federal courts.
[edit] Arrest and conviction of Weeks
Fremont Weeks was arrested in Kansas City, Missouri by a law enforcement officer. During the apprehension, the arresting officer performed a search of Weeks' business, although he did not have a search warrant. The search turned up evidence of violation of federal law, whereby U.S. mail was used to send lottery tickets. The police also searched Weeks’ home, likewise without a warrant, and located other papers that proved to be of no importance to the case. Encouraged by the results of the search of Weeks’ business, a United States marshal, together with a local police officer and a federal postal inspector, searched Weeks’ residence for the third time (again without a warrant), and seized some letters and documents. Weeks filed a complaint in order to retrieve the papers, and petitioned to have the illegally seized evidence excluded from the trial. Weeks was given some of his property, but not all of his property.
[edit] The Court's decision
Weeks, at its core, raised the question of precisely what the Fourth Amendment means and requires. The questions the Court had to answer were whether the Fourth Amendment provides specific protections to citizens and whether illegally obtained evidence can be used in court.
Martin J. O’Donnell presented Mr. Week’s case. He argued that because the Fourth Amendment explicitly states that people should be safe from unlawful searches and seizures, it follows that evidence obtained in violation of this guarantee cannot be used in a court of law. If such a prohibition is not enforced, the language of the Fourth Amendment is meaningless.
Assistant Attorney General Denison and Solicitor General Davis presented the case on behalf of the United States of America. They argued that the prosecution of Mr. Weeks proceeded in a logical sequence, and that the law enforcement officers involved in the arrest and the searches acted upon an increasing body of evidence which incriminated Mr. Weeks in an apparent violation of a federal law. Because Mr. Weeks was in possession of evidence which betrayed his guilt, his transgression should be punished in a court of law.
[edit] Day's opinion for the Court
Associate Justice William R. Day delivered the unanimous opinion of the United States Supreme Court. He wrote that it is the defendant’s contention that appropriation of his private correspondence was in violation of the rights afforded to him by the Fourth and Fifth Amendments of the Constitution of the United States of America. The Court, he continues, will deal with the Fourth Amendment challenge in this matter.
The Fourth Amendment originates in the determination of the framers to secure for the American people certain safeguards to protect them against unreasonable searches and seizures which had been permitted under the warrants issued by the English government. The Fourth Amendment embodies the maxim that a man’s house is his castle, and that it cannot be invaded.3 The Court has recognized this principle of protection, and has specifically extended it to include "letters and sealed packages in the mail."4
The intent of the Fourth Amendment, Justice Day states, is to create restraints upon the exercise of power of the United States and federal officials, and to “forever secure the people, their persons, houses, papers, and effects, against all unreasonable searches and seizures under the guise of law.” The Constitution should not, and does not permit criminal convictions obtained by means of unlawful seizures and forced confessions.
The conclusion reached by the Court is that the confiscation of the defendant’s private correspondence was done so in direct violation of his constitutional rights. Thus, the judgment of the lower court is reversed.
[edit] See also
- Exclusionary rule
- Wolf v. Colorado
- Mapp v. Ohio
- Elkins v. United States
- Boyd v. United States
- Bram v. United States
- Adams v. New York
- Fourth Amendment
- Fifth Amendment
[edit] Footnotes
- Note 1: The Fourth Amendment states: “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”
- Note 2: It is important to note that the Weeks decision prohibited only the admissibility of evidence obtained via an illegal search by a federal officer in a federal court. Following this ruling, it was not uncommon for federal officers and state / local officers to employ “silver platter” arrangements whereby federal officers would prompt local officers to secure evidence by means prohibited under the federal exclusionary rule, and give it to their federal colleagues. It was not until the case of Mapp v. Ohio (1961) that the exclusionary rule was deemed to apply to state courts as well.
- Note 3: “Judge Cooley, in his “Constitutional Limitations,” pp. 425, 426, in treating of this feature of our Constitution said: 'The maxim that 'every man's house is his castle' is made a part of our constitutional law in the clauses prohibiting unreasonable searches and seizures, and has always been looked upon as of high value to the citizen.'” Cited from Justice Day’s opinion.
- Note 4: See Ex parte Jackson, 96 U.S. 727, 733.
