Elkins v. United States
364 U.S. 206 (1960)
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Rule of Law:
Evidence obtained by state officers in a search and seizure that would have violated the Fourth Amendment if conducted by federal officers is inadmissible in a federal criminal trial.
Facts:
- State law enforcement officers received information that petitioners, including Clark, possessed obscene motion pictures.
- Based on this information, the state officers procured a search warrant to search petitioner Clark's home.
- The officers searched Clark's home but did not find obscene pictures.
- During the search, officers found and seized various items believed to be wiretapping paraphernalia, including tape recordings, wire recordings, and a recording machine.
- There was no evidence of any participation by federal officers in the search and seizure.
- Two separate Oregon state courts subsequently found that the state search and seizure had been unlawful.
Procedural Posture:
- Petitioners were indicted in the U.S. District Court in Oregon for federal crimes related to intercepting telephone communications.
- Before trial, petitioners filed a motion to suppress recordings and equipment seized by state officers, arguing the seizure was unlawful.
- The District Court denied the motion, assuming the search was unreasonable but finding no federal officer involvement, and the evidence was admitted.
- The petitioners were convicted in the trial court.
- Petitioners appealed their convictions to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals affirmed the convictions, holding that the absence of federal participation rendered the evidence admissible regardless of the legality of the state search.
- The Supreme Court of the United States granted certiorari.
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Issue:
Is evidence obtained by state officers during an unreasonable search and seizure, conducted without federal involvement, admissible in a federal criminal trial?
Opinions:
Majority - Justice Stewart
No, evidence obtained by state officers during an unreasonable search and seizure is not admissible in a federal criminal trial. The "silver platter" doctrine, which previously allowed federal prosecutors to use evidence illegally seized by state officers, is no longer valid. The Court's 1949 decision in Wolf v. Colorado, which held that the Fourth Amendment's prohibition on unreasonable searches applies to the states through the Fourteenth Amendment, removed the doctrinal foundation for this rule. There is no logical distinction between evidence unconstitutionally seized by a federal agent and that seized by a state officer, as the Constitution is violated in either case. The purpose of the exclusionary rule is to deter unconstitutional conduct by removing the incentive to disregard it, a purpose that is undermined by the silver platter doctrine. Admitting such evidence compromises the imperative of judicial integrity, making federal courts accomplices in the willful disobedience of the Constitution.
Dissenting - Justice Frankfurter
Yes, the evidence should be admissible. The Court's decision overturns a long-standing rule, established in Weeks v. United States, that has been the law for nearly half a century. The majority misinterprets Wolf v. Colorado, which held only that the 'core' of the Fourth Amendment applies to the states and explicitly rejected applying the exclusionary rule to them. The majority wrongly equates the specific protections of the Fourth Amendment with the generalities of the Fourteenth Amendment's Due Process Clause. The exclusionary rule is a tool for federal courts to supervise federal officers, not state officials. It is fanciful to believe that excluding evidence in federal trials will deter state officers whose primary focus is state prosecution, where the evidence may still be admissible. The new rule creates conflicts with state courts and policies, as a federal court may now find a search constitutional that a state court, under its own stricter laws, has deemed illegal.
Analysis:
This landmark decision officially abolished the "silver platter" doctrine, a significant loophole in the Fourth Amendment's exclusionary rule. By preventing federal prosecutors from using unconstitutionally seized evidence handed to them by state officers, the ruling strengthened Fourth Amendment protections and promoted federalism by encouraging consistent constitutional standards between state and federal law enforcement. This case set the stage for Mapp v. Ohio (1961), which would extend the exclusionary rule to the states themselves, making it a cornerstone of modern criminal procedure.
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