Monday, December 23, 2013

United States v. Calandra case brief

United States v. Calandra case brief summary
414 U.S. 338 (1974)

CASE SYNOPSIS
By petition for writ of certiorari, petitioner, the federal government, sought review of a judgment from the United States Court of Appeals for the Sixth Circuit, which ruled that the exclusionary rule could be invoked by respondent, a witness before the grand jury, to bar questioning based on evidence obtained in an unlawful search and seizure.

CASE FACTS
The Court reversed an appellate judgment holding that the exclusionary rule could be invoked by a witness before the grand jury to bar questioning based on evidence obtained in an unlawful search and seizure. Respondent grand jury witness had successfully moved the district court to suppress evidence against him allegedly obtained in violation of his Fourth Amendment rights. The district court ordered the evidence suppressed and ruled that respondent was not required to answer any of the grand jury's questions based on the suppressed evidence.

DISCUSSION

  • The Court reversed, declining to extend the exclusionary rule to grand jury proceedings. 
  • The Court concluded that allowing a grand jury witness to invoke the exclusionary rule would unduly interfere with the effective and expeditious discharge of the grand jury's duties. 
  • In particular, suppression hearings would halt the orderly progress of an investigation and might necessitate extended litigation of issues only tangentially related to the grand jury's primary objective. 
  • Further, any incremental deterrent effect which might be achieved by extending the exclusionary rule to grand jury proceedings was uncertain at best.

CONCLUSION
The Court reversed the judgment.


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