Sunday, November 3, 2013

Weeks v. United States case brief

Weeks v. United States case brief summary
232 U.S. 383 (1914)

Defendant was charged with the use of the mails to transport coupons or tickets representing chances or shares in a lottery. The District Court of the United States for the Western District of Missouri denied defendant's pretrial petition to suppress the evidence seized in a warrantless search of his room and to return the seized property. The district court retained jurisdiction of the property. Defendant appealed the denial of his petition.


  • In review of defendant's contention that the warrantless seizure of his private correspondence violated his Fourth Amendment rights, the Court held: 
  • 1) that the letters in question were taken from defendant's house by an official of the United States acting under color of his office in direct violation of the constitutional rights of defendant; 
  • 2) that having made a seasonable application for their return, which was heard and passed upon by the court, there was involved in the order refusing the application a denial of the constitutional rights of defendant; and 
  • 3) that the district court should have restored the letters to defendant. 
  • In holding the private correspondence and permitting their use at trial, prejudicial error was committed. 
  • The police did not act under any claim of federal authority such as would make the Fourth Amendment applicable to such unauthorized seizure as they acted before the finding of an indictment in the federal court. 
  • The Court did not inquire as to what remedies were available to defendant, as the Fourth Amendment was not directed to individual misconduct of such officials. 
  • Its limitations reached only the federal government and its agencies.


The Court reversed the judgment of the district court and remanded the case.

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

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