Weeks v. United States

Weeks v. United States Case Brief

United States Supreme Court
232 U.S. 383 (1914)

ISSUE: Should the trial judge have excluded evidence obtained from a search of D's home conducted in violation of the 4th Amdt.?
HOLDING: Yes.
FACTS:
  • D was indicted for using the mail to transport lottery tickets in violation of the criminal code
  • Police went to D's house and used a key to enter that a neighbor had told them where it was kept
  • Police took possession of various papers and articles and turned them over to the US Marshal
  • Officers returned again with the marshal and were let in by someone in the house, probably a boarder
PROCEDURAL HISTORY:
  • D filed a petition for return of the property taken by the police in violation of his constitutional rights
    • Trial judge granted petition insofar as the evidence that was not going to be used against D at trial
  • Evidence was admitted over D's objection at trial
REASONING:
  • 4th Amdt. violation: If letters and private documents could be seized by the govt. and used in evidence against an accused, the protection of the 4th Amdt. would be of no value and might as well be written out of the Constitution = 1st statement of the exclusionary rule
    • Evidence was obtained in direct violation of D's constitutional rights = prejudicial error committed
COMMENTS:
  • Exclusionary rule: Court-made; designed to remedy and deter violations of the suspect's constitutional rights
    • Violation of 4th Amdt. = default presumption of exclusion
    • Weeks only applied to federal govt. (until Mapp)

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