Sunday, December 22, 2013

Alderman v. United States case brief

Alderman v. United States case brief summary
394 U.S. 165 (1969)

CASE SYNOPSIS
Respondent filed a motion to modify an order from the United States Supreme Court, which granted a rehearing as to petitioners' convictions for various crimes because respondent engaged in surveillance that might have violated petitioners' rights under U.S. Constitutional Amendment IV. Respondent argued that the surveillance records should have been subject to in camera review and that only relevant materials should have been released to petitioners.

CASE FACTS
Respondent filed a motion that sought to modify an order for rehearing as to petitioners' convictions for various crimes, premised on a finding that respondent engaged in electronic surveillance that might have violated petitioners' rights under U.S. Constitutional Amendment IV. Respondent argued that the surveillance records should have undergone an in camera inspection by a trial court judge and that only those materials arguably relevant to the prosecution should have been given to petitioners.

DISCUSSION

  • The Court held that the exclusionary rule, which excluded from admission at trial any evidence seized in violation of a defendant's rights, was applicable if respondent unlawfully overheard petitioners' conversations or conversations occurring on petitioners' premises, even if they were not present, or did not participate in, the conversations. 
  • The Court further held the surveillance records, to which petitioners had standing to object, were to be turned over without being screened in camera, in order to enable petitioners to find evidence demonstrating the evidence was tainted. 
  • Accordingly, respondent's motion, to the extent it requested an initial in camera review, was denied.

CONCLUSION
The motion to modify the order for rehearing was denied and case remanded because petitioners were entitled to review the surveillance record, without an initial in camera review, in order to discover and produce evidence that the surveillance should have been excluded because respondent violated petitioners' rights underU.S. Constitutional Amendment IV in collecting the evidence.


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