United States v. Payner - 447 U.S. 727, 100 S. Ct. 2439 (1980)

Rule:

A court may not exclude evidence under the Fourth Amendment unless it finds that an unlawful search or seizure violated the defendant's own constitutional rights. A defendant's Fourth Amendment rights are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party.

Facts:

Defendant Payner was indicted on a charge of falsifying a federal income tax return in violation of 18 U.S.C.S. § 1001. Defendant's indictment was based on evidence illegally seized from a third party. Although the third party search did not impinge upon defendant's Fourth Amendment rights, the district court believed that the Due Process Clause of the Fifth Amendment and the inherent supervisory power of the federal courts required it to exclude evidence from such an illegal search. Defendant’s conviction was set aside. The United States Circuit Court of Appeals for the Sixth Circuit affirmed but did not decide the due process question. The government sought a writ of certiorari.

Issue:

Did the district court err in suppressing the evidence that was illegally seized from a third party?

Answer:

Yes.

Conclusion:

On the grant of certiorari, the Court held that the evidence should not have been suppressed. Defendant lacked standing under the Fourth Amendment to suppress the documents illegally seized from the third party. Also, the supervisory power did not authorize a federal court to suppress otherwise admissible evidence on the ground that it was seized unlawfully from a third party not before the court. Such use of the federal court's supervisory power to suppress evidence upset the careful balance of interests embodied in the Fourth Amendment and would have enabled federal courts to exercise a standardless discretion in their application of the exclusionary rule.