Walder v. United States
347 U.S. 62, 1954 U.S. LEXIS 2453, 98 L. Ed. 2d 503 (1954)
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Rule of Law:
Illegally obtained evidence that has been suppressed under the exclusionary rule may nevertheless be used by the prosecution to impeach a defendant's credibility if the defendant, on direct examination, makes sweeping, false statements that go beyond a mere denial of the specific crime charged.
Facts:
- In February 1950, federal agents conducted an unlawful search of Walder's home and seized a capsule containing heroin.
- In a subsequent case in January 1952, Walder was indicted for four separate illicit narcotics transactions, unrelated to the 1950 seizure.
- At his 1952 trial, Walder took the stand in his own defense.
- On direct examination, Walder's attorney asked him if he had ever sold, possessed, or handled any narcotics at any time.
- Walder made a sweeping denial, testifying under oath, "I have never sold any narcotics to anyone in my life" and that he had never possessed narcotics unless prescribed by a physician.
Procedural Posture:
- In May 1950, Walder was indicted in U.S. District Court for possessing heroin from a February 1950 incident.
- Walder moved to suppress the heroin, arguing it was obtained through an unlawful search and seizure.
- The District Court granted the motion to suppress the evidence.
- On the government's motion, the 1950 indictment against Walder was dismissed.
- In January 1952, Walder was indicted on four separate and new narcotics charges.
- Following a trial in U.S. District Court, a jury convicted Walder on the 1952 charges.
- Walder, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit, which affirmed the conviction with one judge dissenting.
- The U.S. Supreme Court granted Walder's petition for a writ of certiorari.
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Issue:
Does the Fourth Amendment's exclusionary rule, which bars the use of illegally seized evidence in the prosecution's case-in-chief, also prevent the government from using such evidence to impeach a defendant's credibility when the defendant voluntarily testifies on direct examination and makes broad, perjurious claims that he has never possessed narcotics?
Opinions:
Majority - Mr. Justice Frankfurter
No. The exclusionary rule does not provide a defendant with a license to commit perjury by making sweeping claims on direct examination. While the government cannot use illegally seized evidence to secure a conviction in its case-in-chief, a defendant cannot use the rule as a shield to make untruthful statements and prevent the government from challenging his credibility. Walder, of his own accord, went beyond a simple denial of the crimes charged and made the broad claim that he had never possessed any narcotics. This affirmative, perjurious testimony "opened the door" for the prosecution to introduce the previously suppressed evidence from the 1950 seizure for the limited purpose of impeachment. The court distinguished this from Agnello v. United States, where the government impermissibly tried to introduce tainted evidence on cross-examination after the defendant had only denied the specific elements of the crime on direct.
Dissenting - Mr. Justice Black and Mr. Justice Douglas
The opinion notes that Justices Black and Douglas dissent but does not provide their reasoning.
Analysis:
This case establishes the crucial "impeachment exception" to the Fourth Amendment's exclusionary rule. It clarifies that the rule's primary purpose is to deter illegal police conduct by forbidding the prosecution from using tainted evidence in its direct case, not to shield a defendant's perjury. The decision creates a significant tactical consideration for criminal defendants; choosing to testify and making broad claims of innocence carries the risk of "opening the door" to otherwise inadmissible evidence. This ruling balances the constitutional protection against unreasonable searches with the judicial system's interest in truth-seeking and preventing defendants from actively misleading a jury.
