Sunday, November 3, 2013

Silverthorne Lumber Company v. United States case brief

Silverthorne Lumber Company v. United States case brief summary
251 U.S. 385 (1920)

CASE SYNOPSIS
Plaintiffs in error, two company owners, sought review of a judgment of the United States District Court for the Western District of New York, which imposed a fine on the company for contempt of court and ordered one of the owners imprisoned until he purged himself of a similar contempt. The judgment was based on the owners' refusal to obey subpoenas and an order to produce books and documents of the company before a federal grand jury.

CASE FACTS
An indictment was brought against the owners for a single charge. After the owners were arrested at their homes, the government held them in custody. Meanwhile, federal law enforcement officials, without any legal authority, went to the company office and obtained books, papers, and documents. An application was made for a return of what had been taken. The government made photographs and copies of material papers and framed a new indictment based upon the knowledge they obtained.

PROCEDURAL HISTORY
The district court ordered return of the originals but impounded the photographs and copies. The subpoenas to produce the originals were served. Although the district court found that all the papers were seized in violation of the owners' constitutional rights, it ordered the owners to comply with the subpoenas.

DISCUSSION
  • On appeal, the court overturned the district court's judgment. Because the government had obtained the company papers by illegal means, the government could not use the knowledge gained from its wrong to frame a new indictment and use the evidence in a prosecution. 
  • The court noted that such use of the knowledge gained from unlawful means would reduce theFourth Amendment to a mere "form of words."

CONCLUSION

The court reversed the judgment of the district court.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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