Silverthorne Lumber Co. v. United States | |
---|---|
Argued December 12, 1919 Decided January 26, 1920 | |
Full case name | Silverthorne Lumber Co., Inc., et al. v. United States |
Citations | 251 U.S. 385 ( more ) 40 S. Ct. 182; 64 L. Ed. 319; 1920 U.S. LEXIS 1685 |
Holding | |
To permit derivatives would encourage police to circumvent the Fourth Amendment, so the illegal copied evidence was held tainted and inadmissible. | |
Court membership | |
| |
Case opinions | |
Majority | Holmes, joined by McKenna, Day, Van Devanter, McReynolds, Brandeis, Clark |
Dissent | White |
Dissent | Pitney |
Silverthorne Lumber Co. v. United States, 251 U.S. 385 (1920), was a U.S. Supreme Court decision in which Silverthorne had attempted to evade paying taxes. Federal agents illegally seized tax books from Silverthorne and created copies of the records. The ruling, delivered by Oliver Wendell Holmes Jr., was that any evidence obtained, even indirectly, from an illegal search was inadmissible in court. He reasoned that otherwise, police would have an incentive to circumvent the Fourth Amendment to obtain derivatives of the illegally obtained evidence. [1] This precedent later became known as the "fruit of the poisonous tree doctrine," [2] and is an extension of the exclusionary rule.
Chief Justice Edward Douglass White and Associate Justice Mahlon Pitney dissented without a written opinion.
The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures and sets requirements for issuing warrants: warrants must be issued by a judge or magistrate, justified by probable cause, supported by oath or affirmation, and must particularly describe the place to be searched and the persons or things to be seized.
Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is a corporate law case of the United States Supreme Court concerning taxation of railroad properties. The case is most notable for a headnote stating that the Equal Protection Clause of the Fourteenth Amendment grants constitutional protections to corporations.
Mapp v. Ohio, 367 U.S. 643 (1961), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the exclusionary rule, which prevents prosecutors from using evidence in court that was obtained by violating the Fourth Amendment to the U.S. Constitution, applies not only to the federal government but also to the state governments. The Supreme Court accomplished this by use of a principle known as selective incorporation. In Mapp this involved the incorporation of the provisions, as interpreted by the Court, of the Fourth Amendment which is applicable only to actions of the federal government into the Fourteenth Amendment's due process clause which is applicable to actions of the states. Citing Boyd v. United States, the Court opined, "It is not the breaking of his doors, and the rummaging of his drawers, that constitutes the essence of the offense; but it is the invasion of his indefeasible right of personal security, personal liberty and private property."
William Rufus Day was an American diplomat and jurist who served as an associate justice of the Supreme Court of the United States from 1903 to 1922. Prior to his service on the Supreme Court, Day served as United States Secretary of State during the administration of President William McKinley. He also served as a United States circuit judge of the United States Court of Appeals for the Sixth Circuit and the United States Circuit Courts for the Sixth Circuit.
Fruit of the poisonous tree is a legal metaphor used to describe evidence that is obtained illegally. The logic of the terminology is that if the source of the evidence or evidence itself is tainted, then anything gained from it is tainted as well.
In the United States, the exclusionary rule is a legal rule, based on constitutional law, that prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be considered an example of a prophylactic rule formulated by the judiciary in order to protect a constitutional right. The exclusionary rule may also, in some circumstances at least, be considered to follow directly from the constitutional language, such as the Fifth Amendment's command that no person "shall be compelled in any criminal case to be a witness against himself" and that no person "shall be deprived of life, liberty or property without due process of law."
Missouri v. Seibert, 542 U.S. 600 (2004), is a decision by the Supreme Court of the United States that struck down the police practice of first obtaining an inadmissible confession without giving Miranda warnings, then issuing the warnings, and then obtaining a second confession. Justice David Souter announced the judgment of the Court and wrote for a plurality of four justices that the second confession was admissible only if the intermediate Miranda warnings were "effective enough to accomplish their object." Justice Anthony Kennedy wrote in a concurring opinion that the second confession should be inadmissible only if "the two-step interrogation technique was used in a calculated way to undermine the Miranda warning."
Parallel construction is a law enforcement process of building a parallel, or separate, evidentiary basis for a criminal investigation in order to conceal how an investigation actually began.
Roberto Reyes Concepcion was the Chief Justice of the Supreme Court of the Philippines from June 17, 1966, until April 18, 1973. He is remembered in the history of the Philippine Supreme Court for protecting the independence of court, and for having fought decisions which would have legitimized the dictatorship of President Ferdinand Marcos. In recognition of his efforts against authoritarian rule, Concepcion's name was inscribed on the Wall of Remembrance at the Bantayog ng mga Bayani in 1994.
Inevitable discovery is a doctrine in United States criminal procedure that permits admission of evidence that was obtained through illegal means if it would "inevitably" have been obtained regardless of the illegality. It is one of several exceptions to the exclusionary rule, or the related fruit-of-the-poisonous tree doctrine, which prevent evidence collected in violation of a defendant's constitutional rights from being admitted in court.
The Fifth Amendment to the United States Constitution creates several constitutional rights, limiting governmental powers focusing on criminal procedures. It was ratified, along with nine other articles, in 1791 as part of the Bill of Rights.
Wong Sun v. United States, 371 U.S. 471 (1963), is a United States Supreme Court decision excluding the presentation of verbal evidence and recovered narcotics where they were both fruits of an illegal entry. Narcotics agents unlawfully entered Toy's laundry at which point Toy indicated that Jonny was selling narcotics. The drug agents then went to Jonny and found the narcotics. Jonny made a deal to give up his supplier, Wong Sun. The agents then arrested Wong Sun. All were arraigned and released on their own recognizance. Several days later, Wong Sun voluntarily returned to the police station to make a statement, during the process of which he confessed.
Schmerber v. California, 384 U.S. 757 (1966), was a landmark United States Supreme Court case in which the Court clarified the application of the Fourth Amendment's protection against warrantless searches and the Fifth Amendment right against self-incrimination for searches that intrude into the human body. Until Schmerber, the Supreme Court had not yet clarified whether state police officers must procure a search warrant before taking blood samples from criminal suspects. Likewise, the Court had not yet clarified whether blood evidence taken against the wishes of a criminal suspect may be used against that suspect in the course of a criminal prosecution.
Warden v. Hayden, 387 U.S. 294 (1967), was a United States Supreme Court case that held that 'mere evidence' may be seized and held as evidence in a trial, allowing such evidence obtained in a search to be used. This finding reversed previous Supreme Court decisions such as Boyd v. United States which had held that search warrants may not be used as a means of gaining access to a man's house or office and papers solely for the purpose of making search to secure evidence to be used against him in a criminal or penal proceeding...
James v. Illinois, 493 U.S. 307 (1990), was a United States Supreme Court case in which the Court forbade the admission of evidence obtained in violation of the Fourth Amendment for the use of impeaching statements made by a defense witness.
United States v. Payner, 447 U.S. 727 (1980), is a United States Supreme Court case in which the Court reversed a district court's suppression of evidence in the criminal prosecution of an Ohio businessman charged with tax evasion. The case concerned both issues of criminal procedure and the application of the exclusionary rule derived from the Fourth Amendment. By a 6–3 margin the Court both reaffirmed its earlier rulings' holding that only the party whose Fourth Amendment protections may have been violated has standing to challenge the evidence seized in the search, and barred lower courts from exercising their supervisory power to exclude such evidence at the trial of third parties.
United States v. Janis, 428 U.S. 433 (1976), was a Supreme Court Case that found Max Janis and Morris Levine guilty of illegal bookmaking activities in Los Angeles in a 5-3 ruling. The two were arrested for the crime in November 1968. Appealing on the grounds of unconstitutionally seized evidence, Janis and Levine were heard by the 9th Circuit Court of Appeals in 1973. The case was ultimately heard by the Supreme Court in 1975, and the two were found guilty in 1976. More importantly, the case established that the exclusionary rule does not apply to civil cases where evidence is unconstitutionally seized by a state officer but used by a federal institution.
Murray v. United States, 487 U.S. 533 (1988), was a United States Supreme Court decision that created the modern "independent source doctrine" exception to the exclusionary rule. The exclusionary rule makes most evidence gathered through violations of the Fourth Amendment to the United States Constitution inadmissible in criminal trials as "fruit of the poisonous tree". In Murray, the Court ruled that when officers conduct two searches, the first unlawful and the second lawful, evidence seized during the second search is admissible if the second search "is genuinely independent of [the] earlier one."
Colorado v. Spring, 479 U.S. 564 (1987), was a United States Supreme Court case in which the Court held that a suspect's awareness of the crimes about which he may be questioned is not relevant to his waiver of his Fifth Amendment rights.
Brown v. Illinois, 422 U.S. 590 (1975), was a case in which the Supreme Court of the United States held that the Fourth Amendment's protection against the introduction of evidence obtained in an illegal arrest is not attenuated by reading the defendant their Miranda Rights.