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Law School Case Brief

Weeks v. United States - 232 U.S. 383, 34 S. Ct. 341 (1914)

Rule:

The Fourth Amendment places the United States courts and federal officials, in the exercise of their power and authority, under limitations and restraints as to the exercise of such power and authority, and to forever secure the people, their persons, houses, papers and effects against all unreasonable searches and seizures under the guise of law. This protection reaches all alike, whether accused of crime or not, and the duty of giving to it force and effect is obligatory upon all entrusted under our federal system with the enforcement of the laws. The tendency of those who execute the country's criminal laws to obtain conviction by means of unlawful seizures and enforced confessions, the latter often obtained after subjecting accused persons to unwarranted practices destructive of rights secured by the Constitution, find no sanction in the judgments of the courts which are charged with the support of the Constitution and to which people of all conditions have a right to appeal for the maintenance of such fundamental rights. 

Facts:

Defendant Weeks was arrested by a police officer, without warrant, at the Union Station in Kansas City, Missouri, where he was employed by an express company. Other police officers had gone to Weeks' house, and being told by a neighbor where to find the key, entered the house. They searched Weeks' room and took possession of various papers and articles, which were afterwards turned over to the United States Marshal. Later in the same day, police officers returned with the marshal, and after being let into the home by a third party, the marshal searched Weeks' room and carried away certain letters and envelopes found in the drawer of a chiffonier. Neither the marshal nor the police officers had a search warrant. Weeks was charged in federal district court with the use of the mails to transport coupons or tickets representing chances or shares in a lottery. The district court denied Weeks' pretrial petition to suppress the evidence seized in the warrantless searches of his room and to have the seized property returned to him. The district court retained jurisdiction of the seized property. Weeks appealed the denial of his petition.

Issue:

Did the warrantless seizure of Weeks' private correspondence violate his Fourth Amendment rights?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States held that: 1) the letters in question were taken from Weeks' house by an official of the United States acting under color of his office in direct violation of the constitutional rights of Weeks; 2) having made a seasonable application for their return, which was heard and passed upon by the court, there was involved in the order refusing the application a denial of the constitutional rights of Weeks; and 3) the district court should have restored the letters to Weeks. In holding the private correspondence and permitting their use at trial, prejudicial error was committed. The police did not act under any claim of federal authority such as would make the Fourth Amendment applicable to such unauthorized seizure as they acted before the finding of an indictment in the federal court. The Court did not inquire as to what remedies were available to Weeks, as the Fourth Amendment was not directed to individual misconduct of such officials. Its limitations reached only the federal government and its agencies.

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