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Weeks v. United States

Supreme Court of the United States · 1914 · Criminal Procedure

Criminal ProcedureFourth Amendmentexclusionary rulefederal courtsFourth Amendmentunreasonable searches and seizuresfederal officersUnited States Marshal

Facts

Weeks was arrested without a warrant at his workplace, and police officers entered his house, searched his room, and took various papers and articles that were later turned over to the United States Marshal. Later that same day, the Marshal, without a search warrant and for the purpose of finding additional evidence, entered the house and searched Weeks's room, taking letters and envelopes from a drawer. Before trial, Weeks petitioned for the return of his private papers and other property, asserting violations of the Fourth and Fifth Amendments. The district court returned non-pertinent items but retained papers it considered pertinent, and those letters and other papers were later introduced against him at trial over objection.

Issue

When a United States Marshal, acting under color of federal office and without a warrant, seizes a defendant's private letters and papers from his home, may a federal court refuse the defendant's timely motion to return them and then permit the government to use them in evidence at trial? More broadly, what is the duty of a federal court when federal officers obtain evidence by a search and seizure that violates the Fourth Amendment?

Rule

The Fourth Amendment restrains the federal government and its officers from invading a person's house and seizing private papers without a warrant issued on sworn information and particularly describing the place and things to be searched and seized. When federal officers unlawfully seize a defendant's private papers in violation of the Fourth Amendment, and the defendant makes a seasonable application for their return before trial, the federal court must restore them and may not retain and admit them in evidence against the accused.

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

Federal postal inspectors suspected Nora Benton of using the mail to promote an illegal scheme in St. Louis, Missouri. Without obtaining any warrant, an inspector entered Nora's apartment while she was at work, opened a desk drawer, and took her personal letters and account notes, which were then given to the federal prosecutor; before trial, Nora moved for return of the papers.

How should the federal trial court rule on Nora's motion and on the government's attempt to introduce the papers at trial?

Explanation. When a federal officer, acting under color of federal office, invades a person's home without a warrant and seizes private papers, the seizure violates the Fourth Amendment. If the accused makes a seasonable application before trial for return of those papers, the federal court must restore them and may not retain and admit them in evidence. The majority rejected the idea that a court may simply keep relevant papers once they are in its control.