Summary
The Supreme Court held that a federal district court could enjoin a federal narcotics agent from using or presenting in a state prosecution evidence obtained through an unlawful federal search. The Court characterized the issue as one involving federal courts’ supervisory authority over federal law enforcement and enforcement of the federal Rules of Criminal Procedure, rather than a constitutional question concerning state proceedings. The judgment of the Court of Appeals was reversed.
Topics
Practice areas
Questions Presented
- Whether a federal district court may enjoin a federal law-enforcement agent from testifying in a state prosecution about evidence obtained through a search conducted in violation of the Federal Rules of Criminal Procedure.
- Whether the requested injunction presents a constitutional question concerning the Fourth and Fourteenth Amendments or instead rests on the federal courts' supervisory authority over federal law-enforcement officers.
Holdings
- A federal district court may enjoin a federal agent from testifying about, or otherwise using in a state prosecution, evidence obtained through a violation of the Federal Rules of Criminal Procedure.
- The requested relief did not require resolution of the Fourth and Fourteenth Amendment questions concerning New Mexico's use of the evidence because it was directed solely at a federal agent's compliance with federal law.
Key quotations
“In this posture we have then a case that raises not a constitutional question but one concerning our supervisory powers over federal law enforcement agencies.” (217)
“That policy is defeated if the federal agent can flout them and use the fruits of his unlawful act either in federal or state proceedings.” (218)
Factual background
A federal narcotics agent obtained marihuana under a search warrant that the district court determined was improperly issued under Federal Rule of Criminal Procedure 41. After suppressing the evidence and dismissing the federal indictment, the district court learned that the agent intended to use the evidence and testify about it in a pending New Mexico possession prosecution. Rea sought an injunction against the federal agent, including an order concerning the seized contraband, but the district court denied relief.
Procedural history
Rea was indicted in federal court for unlawful acquisition of marihuana. The district court granted Rea's Rule 41(e) suppression motion and later dismissed the indictment, but denied his subsequent request to prevent a federal agent from assisting a state prosecution with the suppressed evidence. The Tenth Circuit affirmed, and the Supreme Court granted certiorari and reversed.