Weeks v. United States
Encyclopedia
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
. It also set forth the exclusionary rule
that prohibits admission of illegally obtained evidence in federal courts
.
. State agents entered his home, searched his room, and took possession of papers and other property belonging to the defendant. 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 neither instance did the police have a search warrant.
, 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.
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
which violated the fourth amendment. 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.
by a law enforcement officer. During the apprehension, the arresting officer performed a search of Weeks's 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’s home, a United States marshal, together with a local police officer and a federal postal inspector, searched Weeks’s 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.
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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1914), the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
unanimously held that the warrantless seizure of items from a private residence constitutes a violation of the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
. It also set forth the exclusionary rule
Exclusionary rule
The exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
that prohibits admission of illegally obtained evidence in federal courts
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
.
Why police searched
Fremont Weeks was suspected of using the mail system to distribute chances in a lottery, which was considered gambling and was at the time illegal in MissouriMissouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
. State agents entered his home, searched his room, and took possession of papers and other property belonging to the defendant. 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 neither instance did the police 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 lawCommon law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
, 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.
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
Search and seizure
Search and seizure is a legal procedure used in many civil law and common law legal systems whereby police or other authorities and their agents, who suspect that a crime has been committed, do a search of a person's property and confiscate any relevant evidence to the crime.Some countries have...
which violated the fourth amendment. 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, MissouriKansas City, Missouri
Kansas City, Missouri is the largest city in the U.S. state of Missouri and is the anchor city of the Kansas City Metropolitan Area, the second largest metropolitan area in Missouri. It encompasses in parts of Jackson, Clay, Cass, and Platte counties...
by a law enforcement officer. During the apprehension, the arresting officer performed a search of Weeks's home, although he did not have a search warrant
Search warrant
A search warrant is a court order issued by a Magistrate, judge or Supreme Court Official that authorizes law enforcement officers to conduct a search of a person or location for evidence of a crime and to confiscate evidence if it is found....
. 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’s home, a United States marshal, together with a local police officer and a federal postal inspector, searched Weeks’s 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.
See also
- List of United States Supreme Court cases, volume 232
- Exclusionary ruleExclusionary ruleThe exclusionary rule is a legal principle in the United States, under constitutional law, which holds that evidence collected or analyzed in violation of the defendant's constitutional rights is sometimes inadmissible for a criminal prosecution in a court of law...
- Wolf v. ColoradoWolf v. ColoradoWolf v. Colorado, 338 U.S. 25 was a United States Supreme Court case in which the Court held 6-3 that the Fourth Amendment was applicable to the States through the Due Process Clause of the Fourteenth Amendment, however, the exclusionary rule was not. The Court specified no redressive measures...
- Mapp v. OhioMapp v. OhioMapp v. Ohio, , was a landmark case in criminal procedure, in which the United States Supreme Court decided that evidence obtained in violation of the Fourth Amendment, which protects against "unreasonable searches and seizures," may not be used in criminal prosecutions in state courts, as well as...
- Elkins v. United States
- Boyd v. United StatesBoyd v. United StatesBoyd v. United States, , was a decision by the United States Supreme Court, which held that “a search and seizure [was] equivalent [to] a compulsory production of a man's private papers” and that the search was “an 'unreasonable search and seizure' within the meaning of the Fourth Amendment.”In the...
- Bram v. United States
- Adams v. New York
- Fourth AmendmentFourth Amendment to the United States ConstitutionThe Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
- Fifth AmendmentFifth Amendment to the United States ConstitutionThe Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...