United States v. Jeffers
342 U.S. 48 (1951)
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Rule of Law:
A person has standing to challenge the illegal seizure of their property under the Fourth Amendment, even if the property is contraband and is seized from a location where they do not have a primary expectation of privacy but have permission to be. The fact that an item is contraband in which Congress has declared "no property rights shall exist" does not eliminate a person's Fourth Amendment interest for the purpose of seeking the suppression of that evidence.
Facts:
- The Misses Jeffries rented a hotel room at the Dunbar Hotel.
- They gave their nephew, Jeffers, a key to the room and permission to use it at will.
- Without his aunts' knowledge, Jeffers stored a pasteboard box containing nineteen bottles of cocaine and one bottle of codeine in a closet in their room.
- An informant, Roberts, told the hotel's house detective that Jeffers had narcotics stored in the room.
- The house detective reported this information to the Metropolitan Police.
- Police officers, without an arrest or search warrant, obtained a key from hotel management.
- The officers then entered and searched the room while it was unoccupied, discovering and seizing the narcotics owned by Jeffers.
- Jeffers was arrested the following day and admitted that the seized narcotics belonged to him.
Procedural Posture:
- Jeffers was charged in U.S. District Court with violating federal narcotics laws.
- Jeffers filed a pretrial motion to suppress the seized narcotics as evidence, which the District Court denied.
- Following a trial, Jeffers was convicted.
- Jeffers, as appellant, appealed his conviction to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals reversed the conviction, holding the evidence should have been suppressed.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a defendant have standing to move to suppress his contraband property as evidence when it was seized during an unlawful, warrantless search of a third party's premises which he had permission to use?
Opinions:
Majority - Mr. Justice Clark
Yes. A defendant has standing to challenge the seizure of his property, even if it is contraband, when it is taken during an unlawful search of another person's premises that he has permission to use. The Fourth Amendment protects against unreasonable seizures of "effects" as well as unlawful searches of "houses." The warrantless search of the hotel room was clearly unlawful, as no exigent circumstances existed. The government's argument that the search did not invade Jeffers's personal privacy is a "quibbling distinction," because the sole purpose of the illegal entry and search was to locate and seize Jeffers's property; therefore, the search and seizure are "incapable of being untied." The Court also rejected the government's argument that Jeffers lacked a property interest in the contraband, reasoning that the statute declaring "no property rights shall exist" in such goods was intended to aid in their forfeiture, not to abolish the Fourth Amendment's exclusionary rule. For the purpose of a motion to suppress, the narcotics were Jeffers's property.
Analysis:
This decision solidifies the principle that standing to challenge a Fourth Amendment violation can arise from an interest in the property seized, not just from a privacy interest in the place searched. It prevents law enforcement from targeting an individual's property by illegally searching a third party's premises and then arguing the property owner lacks standing to object. This case distinguishes between the possessory interest in one's "effects" and the privacy interest in a "house," affirming that a violation of either can trigger the exclusionary rule. It clarifies that statutory declarations abrogating property rights in contraband do not strip away a defendant's ability to challenge the legality of the seizure itself.
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