Rea v. United States
100 L. Ed. 2d 233, 1956 U.S. LEXIS 1488, 350 U.S. 214 (1956)
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Rule of Law:
Federal courts, through their supervisory power over federal law enforcement agents, may enjoin a federal agent from testifying in a state criminal prosecution about evidence obtained by that agent in violation of the Federal Rules of Criminal Procedure.
Facts:
- A federal narcotics agent obtained a search warrant from a United States Commissioner to search the petitioner's property.
- Pursuant to the warrant, the agent searched the property and seized marihuana, which was considered contraband under federal law.
- The evidence was seized for an alleged violation of the Internal Revenue Code related to the unlawful acquisition of marihuana.
- After a federal court found the search warrant to be invalid, the same federal agent swore out a complaint before a New Mexico judge, initiating state criminal proceedings against the petitioner.
- The federal agent planned to testify in the New Mexico state prosecution based on the illegal search and the evidence seized under the invalid federal warrant.
Procedural Posture:
- The petitioner was indicted in U.S. District Court for unlawful acquisition of marihuana.
- Petitioner filed a motion to suppress the evidence, arguing the search warrant was invalid under the Federal Rules of Criminal Procedure.
- The District Court granted the motion to suppress.
- On the government's motion, the District Court dismissed the indictment.
- Petitioner then filed a new motion in the District Court to enjoin the federal agent from testifying in a pending state prosecution and to compel the destruction of the seized evidence.
- The District Court denied the petitioner's motion for an injunction.
- The petitioner (as appellant) appealed to the U.S. Court of Appeals, which affirmed the District Court's decision.
- The petitioner sought and was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a federal court have the authority, under its supervisory powers over federal law enforcement, to enjoin a federal agent from testifying in a state criminal proceeding about evidence the agent obtained through a search that violated the Federal Rules of Criminal Procedure?
Opinions:
Majority - Mr. Justice Douglas
Yes. A federal court has the authority to enjoin a federal agent from using illegally obtained evidence in a state proceeding. This case does not present a constitutional question regarding the Fourth or Fourteenth Amendments, but rather one concerning the Supreme Court's supervisory powers over federal law enforcement agencies. The Federal Rules of Criminal Procedure are designed as standards for federal agents, and that policy is defeated if an agent can flout those rules and use the fruits of his unlawful act in either federal or state proceedings. To enjoin the agent from testifying is not to interfere with state officials but is merely to enforce federal rules against those, like federal agents, who owe obedience to them.
Dissenting - Mr. Justice Harlan
No. A federal court should not enjoin a federal law enforcement officer from providing illegally obtained evidence to state authorities for use in a state prosecution. This holding improperly extends the Court's supervisory power from overseeing federal trials to supervising executive law enforcement activities. The decision is contrary to the principles of federalism and comity articulated in Stefanelli v. Minard, which cautioned against federal court interference in state criminal proceedings. Although the injunction is directed only at a federal agent, it effectively stultifies the state prosecution, accomplishing indirectly what federal courts should not do directly.
Analysis:
This decision significantly strengthened the federal courts' supervisory power over federal law enforcement agents, establishing that this power extends beyond the confines of a federal prosecution. It affirmed that federal agents are bound by federal rules regardless of the forum in which the evidence they gather is ultimately used. The ruling effectively closed a loophole in the exclusionary rule, preventing federal agents from circumventing the consequences of an illegal search by handing the evidence over to state prosecutors on a "silver platter," a step that foreshadowed the eventual application of the exclusionary rule to the states in Mapp v. Ohio.
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