United States v. Raddatz

Supreme Court of the United States · 1980 · Federal Courts

Federal CourtsFederal Magistrates Act28 U.S.C. § 636(b)(1)de novo determinationde novo hearingsuppression motioncredibility findingsdue process

Facts

Raddatz was indicted for unlawfully receiving a firearm and moved before trial to suppress incriminating statements he had made to police officers and federal agents. The district court referred the suppression motion to a magistrate for an evidentiary hearing under 28 U.S.C. § 636(b)(1)(B). At that hearing, Raddatz claimed federal agents had induced his statements by promising dismissal if he cooperated, while the agents denied making any such promise. The magistrate found the agents more credible, recommended denial of suppression, and the district court, after reviewing the transcript, objections, memoranda, and hearing oral argument, adopted that recommendation without rehearing live testimony.

Issue

Whether 28 U.S.C. § 636(b)(1)(B) requires a district judge to rehear live testimony before deciding objected-to portions of a magistrate's recommendation on a suppression motion, and whether allowing the judge to decide on the record developed before the magistrate violates the Due Process Clause or Article III.

Rule

Section 636(b)(1) requires a district judge to make a de novo determination of the objected-to portions of a magistrate's proposed findings and recommendations, but it does not require a de novo hearing. The procedure is constitutional so long as the magistrate's role remains subordinate and advisory, the district judge retains ultimate authority to accept, reject, or modify the recommendation, and the judge may receive further evidence or recommit the matter in the exercise of sound judicial discretion.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Denver, Malik Torres moves to suppress statements he made to investigators. The district judge refers the motion to a magistrate judge for an evidentiary hearing, and the magistrate recommends denial. Malik files specific objections to two proposed factual findings, and the district judge reviews the transcript, briefs, and objections before adopting the recommendation without recalling any witnesses.

Which is the strongest argument that the district judge acted lawfully under the governing rule?

Explanation. For dispositive matters such as criminal suppression motions referred under 28 U.S.C. § 636(b)(1)(B), the district judge must make a de novo determination of the portions to which objection is made. But the majority held that this does not require a de novo hearing; the judge may ordinarily decide on the record developed before the magistrate, while retaining authority to accept, reject, modify, take more evidence, or recommit.