Silverthorne Lumber Co. v. United States

Silverthorne Lumber Co. v. United States Case Brief

United States Supreme Court
251 U.S. 385 (1920)

ISSUE: May the Govt. use the knowledge it gained from reading illegally seized documents as evidence against Ds at trial?
HOLDING: No.
PROCEDURAL HISTORY:
  • Ds were indicted on a single charge and were arrested in their home
  • Reps. of the DOJ then went to the office of the company and took all books, papers, and documents found there without any authority
  • All employees were told to go to the DA’s offce
  • Ds petitioned the Dist. Ct. for return of the evidence illegally seized
    • DA said evidence was before the Grand Jury; based on an invalid subpoena for certain documents
    • Dist. Ct. ordered a return of the originals but photographs and copies were retained
  • Subpoenas for the originals were then served upon Ds, and they refused to comply
    • = Contempt
  • Govt. now seeks to avail itself of the knowledge it obtained through the illegal seizure
REASONING:
  • May not use evidence: The essence of the 4th Amdt.’s provision forbidding the acquisition of evidence in a certain way is that not merely evidence so acquired shall not be used before the Court but that it shall not be used at all
    • Allowing knowledge from documents to be used would reduce the 4th Amdt. to a mere form of words
  • Independent Source: If knowledge of them is gained from an independent source, they may be proved like any others, but the knowledge gained by the Govt.’s own wrong cannot be used by it in the way proposed
COMMENTS:
  • Independent Source Doctrine: Is the illegal search the proximate cause of the discovery of the evidence?

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