United States v. Janis case brief

United States v. Janis case brief summary
428 U.S. 433 (1976)

CASE SYNOPSIS

Petitioner United States appealed a judgment from the United States Court of Appeals for the Ninth Circuit in favor of respondent taxpayer on its tax refund claim, quashing a civil tax assessment made by the Internal Revenue Service against his assets, and dismissing petitioner's counterclaim for the unpaid assessment, on the grounds that evidence illegally seized by state officers was improperly excluded under U.S. Const. amend.IV.

CASE FACTS
The Supreme Court reversed a judgment in favor respondent taxpayer on its tax refund claim and dismissing petitioner United States's counterclaim for an unpaid tax assessment because the exclusionary rule created to deter law enforcement agents from violating U.S. Const. amend. IV did not forbid the use in a federal civil proceeding of evidence seized by a state criminal law enforcement agent because the deterrent effect on an offending officer would be too attenuated.

DISCUSSION

• The Court held that empirical studies had not shown that excluding from federal civil proceedings evidence unlawfully seized by a state criminal enforcement officer would be likely to deter the conduct of the state police such that the deterrence would outweigh the societal costs of excluding accurate evidence.
•  Accordingly, the Court declined to extend the exclusionary rule to such civil proceedings.

OUTCOME
The Supreme Court reversed the appellate court's judgment in favor of respondent taxpayer on its tax refund claim.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)