Silverthorne Lumber Company v. United States

Supreme Court of the United States
(1929)

ELI5:

Rule of Law:

The Fourth Amendment protects against not only the direct use of evidence obtained in an illegal search and seizure, but also the derivative use of knowledge gained from that illegality to obtain the same or other evidence.

Facts:

An indictment on a single charge was brought against Frederick W. Silverthorne and his father.
On February 25, 1919, both Silverthornes were arrested at their homes and detained for several hours.
While the Silverthornes were in custody, representatives of the Department of Justice and a U.S. marshal went to the office of the Silverthorne Lumber Company.
Without a warrant or any valid authority, the government agents seized all the books, papers, and documents found in the company's office.
Government agents then made photographs and copies of the material papers they had seized.
Based on the knowledge obtained from the illegally seized documents, the government framed a new indictment against the Silverthornes.

Procedural Posture:

The Silverthornes applied to the U.S. District Court for the return of their illegally seized books and papers.
The District Court ordered the original documents to be returned but impounded the photographs and copies the government had made.
The government then served subpoenas on the Silverthornes to produce the original documents.
The Silverthornes refused to produce the documents as ordered by the subpoenas.
The District Court held the Silverthorne Lumber Company and Frederick W. Silverthorne in contempt of court for their refusal.
The Silverthornes brought a writ of error to the U.S. Supreme Court to reverse the judgment of contempt.

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Issue:

Does the Fourth Amendment's protection against unreasonable searches and seizures prevent the government from compelling the production of evidence via subpoena when the knowledge of that evidence was gained through a prior illegal search?

Opinions:

Majority - Mr. Justice Holmes

Yes. The Fourth Amendment's protection against unreasonable searches and seizures prevents the government from compelling production of evidence via subpoena when its knowledge of that evidence was gained through a prior illegal search. To allow the government to use knowledge gained from its own illegal acts would reduce the Fourth Amendment to a mere "form of words." The essence of the Fourth Amendment's prohibition is that evidence obtained through a constitutional violation shall not be used at all. While the facts themselves do not become "sacred and inaccessible" if knowledge of them is gained from an independent source, the knowledge gained by the government’s own wrongdoing cannot be used to its advantage. The rights of a corporation against unlawful search and seizure are protected just as an individual's are.

Dissenting - The Chief Justice and Mr. Justice Pitney

The Chief Justice and Mr. Justice Pitney dissented without a written opinion.

Analysis:

This case is foundational for establishing what would become known as the "fruit of the poisonous tree" doctrine. It significantly expands the exclusionary rule established in Weeks v. United States, moving beyond the mere suppression of illegally seized items themselves. By prohibiting the use of knowledge derived from an illegal search, the decision removes the incentive for law enforcement to conduct unconstitutional searches to obtain leads or discover other evidence. This precedent forces the government to demonstrate that its evidence was obtained from a legitimate, independent source, thereby strengthening the practical protections of the Fourth Amendment.

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