Weeks v. United States

Supreme Court of United States
232 U.S. 383 (1914)

ELI5:

Rule of Law:

The warrantless seizure of items from a private residence by a federal official violates the Fourth Amendment, and such illegally obtained evidence must be excluded from use in a federal criminal prosecution if the defendant makes a timely motion for its return before trial.

Facts:

Fremont Weeks was employed by an express company in Kansas City, Missouri.
While Weeks was at his job, local police officers went to his home without a search warrant.
The police learned where a key was kept from a neighbor, used it to enter the house, and seized various papers and other articles.
Later that same day, the police officers returned to the house with a United States Marshal.
The U.S. Marshal, also acting without a warrant, entered Weeks' room and seized additional letters and envelopes found in a drawer.
The items seized by both the police and the U.S. Marshal were turned over to the U.S. District Attorney for use as evidence in a prosecution against Weeks for illegally using the mails to transport lottery tickets.

Procedural Posture:

Fremont Weeks was indicted in the U.S. District Court for the Western District of Missouri for the illegal use of mails.
Before trial, Weeks filed a petition in the district court for the return of his private papers, alleging they were seized in violation of the Fourth and Fifth Amendments.
The district court granted the petition in part, ordering the return of items not pertinent to the criminal charge, but denied the petition as to the incriminating evidence.
At the beginning of the trial, Weeks renewed his petition for the return of the property, which the court again denied.
The government introduced the seized papers as evidence at trial over Weeks' objection.
Weeks was convicted and subsequently sought a writ of error from the United States Supreme Court.

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Issue:

Does the use of evidence obtained through a warrantless search by a federal official in a federal criminal trial violate the Fourth Amendment's prohibition against unreasonable searches and seizures?

Opinions:

Majority - Mr. Justice Day

Yes, the use of evidence obtained through a warrantless search by a federal official violates the Fourth Amendment's prohibition against unreasonable searches and seizures. The Fourth Amendment's protections against unreasonable searches and seizures apply directly to federal officials and limit their actions. The U.S. Marshal's warrantless search of Weeks' home and seizure of his private correspondence was a direct violation of his constitutional rights. To permit the use of evidence obtained in such a manner would render the Fourth Amendment meaningless. When a defendant makes a timely, pre-trial motion for the return of illegally seized items, the court must return the property and exclude it from evidence. This case is distinguished from precedents like Adams v. New York, where the court declined to address the source of evidence mid-trial, because here the constitutional question was raised properly before the trial began. The court noted, however, that the Fourth Amendment's limitations apply only to the federal government and its agencies, not to the unauthorized actions of the local police officers in this case.

Analysis:

This landmark decision established the exclusionary rule for the federal government, a crucial remedy for Fourth Amendment violations. By prohibiting the use of illegally obtained evidence in federal prosecutions, the Court created a strong deterrent against unlawful searches and seizures by federal law enforcement. This ruling significantly strengthened constitutional protections for individual privacy against federal intrusion. While initially limited to federal actions, the principle laid out in Weeks v. United States would later be extended to the states in Mapp v. Ohio (1961), fundamentally shaping modern criminal procedure across the entire country.

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