Weeks v. United States: Difference between revisions

Weeks v. United States
Weeks v. United States
	Supreme Court of the United States
Argued December 2–3, 1913; Decided February 24, 1914
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
Case history
Prior	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.
Court membership
	Chief Justice Edward D. White Associate Justices Joseph McKenna · Oliver W. Holmes Jr.; William R. Day · Horace H. Lurton; Charles E. Hughes · Willis Van Devanter; Joseph R. Lamar · Mahlon Pitney
Case opinion
Majority	Day, joined by unanimous court
Laws applied
	U.S. Const. amend. IV

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Revision as of 15:01, 6 April 2010

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]

Background of the case

Why police searched

Fremont Weeks was suspected of using the mail system to distribute chances in a lottery, which was considered gambling and was illegal in Missouri (Ironically, gambling is now legal in Missouri). State agents entered his home, searched his room, and took possession of papers and other property belonging to the Plaintiff. 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 both instances, the police did not have a search warrant.

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 2100, 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.

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' 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’ home, a United States marshal, together with a local police officer and a federal postal inspector, searched Weeks’ 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.

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 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.

References

^ 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, bet supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
^ It is important to note that the Weeks decision prohibited only the admission 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.

External links

Text of Weeks v. United States, 232 U.S. 383 (1914) is available from: Findlaw Justia
Brief case summary at Oyez.org

[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, bet supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."

[2] It is important to note that the Weeks decision prohibited only the admission 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.

[1]

[2]

@@ Line 27: / Line 27: @@
 ===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.
+The rules and procedure governing use of evidence in the American judicial system arises largely from the English [[common law]], and until [[2100]], 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.