Adams v. State

Summary

The Indiana Supreme Court held that a search of the defendant’s home conducted pursuant to a jeopardy tax warrant issued to collect a Controlled Substance Excise Tax assessment was unreasonable under the Fourth Amendment. Because the search was unconstitutional, the exclusionary rule barred use of the cocaine discovered during the search in the defendant’s subsequent criminal prosecution. The court reversed the trial court’s denial of the motion to suppress.

Holdings

1. A search of a home pursuant to a jeopardy tax warrant issued solely because the Controlled Substance Excise Tax is statutorily deemed a jeopardy assessment is unreasonable under the Fourth Amendment because the procedure gives revenue officers unfettered discretion and does not require an individualized finding of exigency.
2. Evidence obtained from the unconstitutional search of Adams's home, including evidence derivatively obtained from that search, must be suppressed in the subsequent criminal trial.

Questions Presented

1. Whether a search of a taxpayer's home pursuant to a jeopardy tax warrant issued to collect a Controlled Substance Excise Tax assessment violated the Fourth Amendment.
2. Whether cocaine discovered during that unconstitutional search had to be suppressed in Adams's subsequent criminal prosecution.

Disposition

reversed