Nathanson v. United States
290 U.S. 41, 1933 U.S. LEXIS 961, 54 S. Ct. 11 (1933)
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Rule of Law:
A search warrant violates the Fourth Amendment if it is issued based on an affiant's mere affirmation of suspicion or belief without any statement of the underlying facts or circumstances that would allow a magistrate to find probable cause.
Facts:
- Francis B. Laughlin, a customs agent, suspected that J.J. Nathanson possessed liquor on which import duties had not been paid.
- Laughlin submitted a sworn application for a search warrant stating only that he "has cause to suspect and does believe" that such illegal merchandise was located at Nathanson's private residence.
- The application did not contain any facts or circumstances to support Laughlin's suspicion or belief.
- Based solely on Laughlin's sworn statement of belief, a state judge issued a warrant to search Nathanson's dwelling.
- Under the authority of this warrant, officers searched Nathanson's home and seized certain liquors.
Procedural Posture:
- The United States prosecuted J.J. Nathanson in a federal trial court under a criminal information.
- At trial, Nathanson challenged the admission of seized liquors as evidence, arguing the search warrant was unconstitutional, but the trial court overruled his objection.
- Nathanson was convicted by the trial court.
- Nathanson, as appellant, appealed the conviction to the United States Circuit Court of Appeals.
- The Circuit Court of Appeals affirmed the conviction, holding the warrant was valid under the Tariff Act, which it reasoned allowed for a lower standard than other laws.
- The United States Supreme Court granted certiorari to review the appellate court's decision.
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Issue:
Does a search warrant issued solely upon an affiant's sworn statement of suspicion and belief, without any supporting facts or circumstances, violate the Fourth Amendment's requirement of probable cause?
Opinions:
Majority - Mr. Justice McReynolds
Yes. A search warrant issued solely upon an affiant's sworn statement of suspicion and belief, without any supporting facts or circumstances, violates the Fourth Amendment's requirement of probable cause. The Fourth Amendment's protection against unreasonable searches and seizures applies to all warrants, including those issued under tariff or revenue statutes. Probable cause requires more than a bare assertion of belief by an officer; it requires that the issuing magistrate be presented with facts or circumstances from which the magistrate can independently find probable cause. A mere affirmance of suspicion is not enough to justify the invasion of a private dwelling, as this would make the magistrate a rubber stamp for the police rather than a neutral arbiter.
Analysis:
This case solidifies the principle that the probable cause standard is a factual, not a conclusory, inquiry. It establishes that a magistrate cannot simply rely on an officer's good faith or belief but must be presented with objective facts to justify issuing a warrant. By holding that the Fourth Amendment's standards override statutory provisions that might permit a lower threshold (like the Tariff Act), the decision reinforces the supremacy of constitutional protections. This precedent is fundamental to search and seizure law, ensuring that the judiciary acts as a meaningful check on law enforcement's power to search private property.
