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United States v. Caceres

Supreme Court of United States
440 U.S. 741 (1979)
ELI5:

Rule of Law:

The exclusionary rule does not require the suppression of evidence obtained in violation of an agency's own internal regulations if the evidence itself was not obtained in violation of the Constitution or a federal statute.


Facts:

  • IRS Agent Yee was auditing the 1971 income tax returns of respondent Caceres and his wife.
  • On March 14, 1974, after his wife left the meeting, Caceres offered Agent Yee a $500 "personal settlement" in exchange for a favorable resolution of the audit.
  • Yee reported the offer to his superiors.
  • On January 27, 1975, Caceres again met with Yee and renewed the offer, stating he had $500 to give immediately and another $500 to be paid later.
  • Yee arranged subsequent meetings with Caceres on January 31 and February 6, 1975, to discuss the bribe.
  • During the meetings on January 31 and February 6, Agent Yee wore a concealed radio transmitter, allowing other agents to monitor and record the conversations with his consent.
  • At the January 31 meeting, Caceres gave Yee $500. At the February 6 meeting, he promised an additional $500 and offered $2,000 for help with other tax returns.
  • Internal IRS regulations required prior approval from the Department of Justice for monitoring non-telephone conversations, which was not obtained for the January 31 and February 6 recordings.

Procedural Posture:

  • The United States brought a criminal prosecution against Caceres in U.S. District Court for bribing an IRS agent.
  • Caceres filed a pre-trial motion to suppress the tape recordings of his conversations with Agent Yee on January 31 and February 6.
  • The District Court granted the motion, finding that the recordings were made in violation of IRS regulations and must be excluded.
  • The United States (appellant) appealed the suppression order to the U.S. Court of Appeals for the Ninth Circuit.
  • The Court of Appeals affirmed the District Court's decision to suppress the tapes from the first two meetings.
  • The United States petitioned the Supreme Court of the United States for a writ of certiorari, which was granted.

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Issue:

Does the exclusionary rule require the suppression of evidence obtained in violation of an agency's internal regulations, where the surveillance itself did not violate the Constitution or any federal statute?


Opinions:

Majority - Mr. Justice Stevens

No, the exclusionary rule does not require suppression of the evidence. The violation of an agency's internal regulations, which are not mandated by the Constitution or federal law, does not trigger the application of the exclusionary rule. Neither the Fourth Amendment nor any federal statute, such as Title III of the Omnibus Crime Control and Safe Streets Act, restricts the recording of a conversation with the consent of one of the participants. The exclusionary rule is a remedy primarily intended to deter constitutional violations, not to enforce administrative discipline. Furthermore, Caceres could not have reasonably relied on the internal IRS regulations, and thus their violation did not implicate his due process rights. A rigid application of the exclusionary rule to every regulatory violation could discourage executive agencies from creating additional, self-imposed procedural safeguards for the public.


Dissenting - Mr. Justice Marshall

Yes, the exclusionary rule requires suppression of the evidence. The Due Process Clause requires an executive agency to adhere to the standards it sets to protect individual interests, even if those standards are not constitutionally or statutorily mandated. The IRS regulations governing surveillance were designed to protect significant privacy interests, and the government is not free to disregard them at its convenience. This principle of governmental regularity, established in cases like Vitarelli v. Seaton and Service v. Dulles, is central to due process and does not depend on a defendant's subjective reliance or proof of prejudice. The exclusionary rule is the appropriate sanction to deter such government lawlessness and to preserve judicial integrity by refusing to sanction the fruits of illegal conduct.



Analysis:

This case significantly limits the scope of the exclusionary rule by drawing a sharp distinction between violations of fundamental law (the Constitution and federal statutes) and violations of internal agency regulations. The decision solidifies the principle that the exclusionary rule's primary purpose is to deter constitutional harms, not to serve as a tool for enforcing administrative compliance. This gives executive agencies more operational flexibility, as an inadvertent failure to follow their own non-mandated procedures will not automatically jeopardize a criminal prosecution. The ruling reinforces a narrower view of the exclusionary rule and its application in federal criminal proceedings.

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