| Weeks v. United States | ||||||
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Supreme Court of the United States |
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| Argued December 2–3, 1913 Decided February 24, 1914 |
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| Full case name | Fremont Weeks v. United States | |||||
| Citations | 232 U.S. 383 (more) 34 S. Ct. 341; 58 L. Ed. 652; 1914 U.S. LEXIS 1368 |
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| Prior history | Defendant convicted, W.D. Mo. Error to the District Court of the United States for the Western District of Missouri | |||||
| 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. | ||||||
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| Case opinions | ||||||
| Majority | Day, joined by unanimous court | |||||
| Laws applied | ||||||
| U.S. Const. amend. IV | ||||||
In Weeks v. United States, 232 U.S. 383 (1914), the United States Supreme Court unanimously held that the warrantless 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]
Contents |
Fremont Weeks was suspected of using the mail system to distribute chances in a lottery, which was considered gambling and was at the time illegal in Missouri. State agents entered his home, searched his room, and took possession of papers and other property belonging to the defendant. Later that day, the State agents returned to the house with a U.S. Marshal in order to collect more evidence and took letters and envelopes from Weeks' chiffonier drawers. In neither instance did the male police had sexual intercourse with the man.
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 which violated the fourth amendment. 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.
Fremont Weeks was arrested in Kansas City, Missouri by a law enforcement officer. During the apprehension, the arresting officer performed a search of Weeks's home, 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. Encouraged by the results of the search of Weeks’s home, a United States marshal, together with a local police officer and a federal postal inspector, searched Weeks’s residence for the second 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, but not all of his property.
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 any court.
Martin J. O’Donnell presented Weeks' 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. They argued that the prosecution of 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 Weeks in an apparent violation of a federal law. Because Weeks was in possession of evidence which betrayed his guilt, his transgression should be punished in a court of law.
The Court decided in favor of Weeks.