Law School Case Brief
United States v. Calandra - 414 U.S. 338, 94 S. Ct. 613 (1974)
The exclusionary rule is a judicially created remedy designed to safeguard Fourth Amendment rights generally through its deterrent effect, rather than a personal constitutional right of the party aggrieved.
Respondent John P. Calandra's place of business was searched by federal agents under a warrant issued in connection with a gambling investigation. The warrant specified that the object of the search was to discover and seize bookmaking records and wagering paraphernalia. One agent, who was of a possible federal investigation of loansharking activities, discovered and seized a document that suspected was connected to loansharking record. A federal grand jury investigating loansharking activities later subpoenaed Calandra to ask him about the seized evidence. Calandra refused to testify on Fifth Amendment grounds. After the Government then requested transactional immunity for Calandra, the district court granted Calandra's motion to suppress on the grounds that the affidavit supporting the warrant was insufficient and that the search exceeded the scope of the warrant. The district court further ordered that Calandra need not answer any of the grand jury's questions based on the suppressed evidence. On the Government's appeal, the court of appeals affirmed. The Government was granted a writ of certiorari.
Did the exclusionary rule apply in grand jury proceedings?
The Supreme Court of the United States reversed the appellate court's judgment. The Court ruled that the Fourth Amendment exclusionary rule, which was a judicially-created remedy to safeguard Fourth Amendment rights by deterring unlawful police misconduct, rather than a personal constitutional right of the party aggrieved, was not applicable to grand jury proceedings. The Court reasoned that that allowing a grand jury witness such as Calandra to invoke the exclusionary rule would cause unduly interference with the effective and expeditious discharge of the grand jury's duties and would achieve only a speculative and minimal advance of the rule's purpose of deterring police misconduct. Further, the Court ruled, grand jury questions based on evidence obtained from an illegal search and seizure did not themselves constitute fresh and independent violations of Calandra's Fourth Amendment rights.
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