Summary
The Supreme Court considered whether evidence obtained through an unreasonable search and seizure by state officers, without federal participation, could be admitted in a federal criminal trial. The Court rejected the silver platter doctrine and held that such evidence is inadmissible upon the defendant's timely objection when the search would have violated the Fourth Amendment if conducted by federal officers. The judgment of the Ninth Circuit was vacated and the case was remanded for further proceedings.
Topics
Practice areas
Questions Presented
- Whether evidence obtained by state officers through an unreasonable search and seizure, without participation or knowledge by federal officers, may be admitted over a timely objection in a federal criminal trial.
- Whether a federal court must independently determine whether state officers conducted an unreasonable search and seizure under federal constitutional standards, notwithstanding a state court's determination.
Holdings
- Evidence obtained by state officers during a search that would have violated the defendant's Fourth Amendment immunity if conducted by federal officers is inadmissible over the defendant's timely objection in a federal criminal trial, even when federal officers did not participate in or know of the state search.
- A federal court must independently determine whether state officers conducted an unreasonable search and seizure under federal law, regardless of whether a state court conducted an inquiry or how the state court resolved the issue.
Key quotations
“For these reasons we hold that evidence obtained by state officers during a search which, if conducted by federal officers, would have violated the defendant's immunity from unreasonable searches and seizures under the Fourth Amendment is inadmissible over the defendant's timely objection in a federal criminal trial.” (223-224)
“The test is one of federal law, neither enlarged by what one state court may have countenanced, nor diminished by what another may have colorably suppressed.” (224)
Factual background
Oregon state officers searched petitioner Clark's home under a warrant based on information and belief that he possessed obscene motion pictures and sound recordings. The search did not discover the described materials but uncovered and seized tape and wire recordings and a recording machine allegedly associated with wiretapping. Two Oregon courts found the search and seizure unlawful; the evidence was later obtained by federal officers and introduced in petitioners' federal trial.
Procedural history
Petitioners were indicted in the United States District Court for the District of Oregon for intercepting and divulging telephone communications and conspiring to do so. The district court denied their motion to suppress evidence seized by Oregon officers, reasoning that federal officers had not participated in or known of the state search; the evidence was admitted and petitioners were convicted. The Ninth Circuit affirmed, and the Supreme Court vacated the judgment and remanded.
Remand instructions
The judgment of the Court of Appeals was set aside, and the case was remanded to the District Court for further proceedings consistent with the opinion, including an independent federal determination of whether the state search and seizure was unreasonable.