Monday, December 23, 2013

People v. Martin case brief

People v. Martin case brief summary
290 P.2d 855 (1955)

Defendant was charged with two counts of horse-race bookmaking and two counts of keeping and occupying premises for the purposes of such bookmaking. The State challenged an order of the Superior Court of Los Angeles County (California), which granted defendant's motion to set aside information on the ground that the evidence against him had been obtained in violation of his constitutional rights.

The trial court granted defendant's motion on the ground that all the evidence had been obtained by illegal searches and seizures. Defendant was arrested after being found on two premises used for bookmaking. Defendant contended that when he was arrested, the police officers had unlawfully entered the premises in violation of his constitutional rights. Defendant also claimed that he was a stranger who had been hired to watch the premises. The State argued that because defendant disclaimed any interest in the premises, he lacked standing to challenge use of the evidence.


  • The court declined to uphold the order of the trial court. 
  • First, the court rejected the State's argument and established a vicarious exclusionary rule, by which defendant had standing to challenge the evidence based on claimed violations of constitutional rights of other persons. 
  • The rule was similarly based on the purpose of disallowing the State from using evidence obtained in violation of constitutional guarantees. 
  • However, the court concluded that the police officers' conduct did not constitute an illegal entry into the premises. 
  • They had reasonable cause to believe that offenses were being committed.

The court reversed the order setting aside the information because the evidence obtained as a result of defendant's arrest was not the product of illegal conduct on the part of the police officers.

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