Weeks v. United States, 232 U.S. 383 (1914)

Fremont Weeks was indicted for unlawful use of the mails for transporting lottery tickets in violation of federal statute. He was arrested, without a warrant, by a police officer in Kansas City, Missouri, at his place of employment. Other officers had gone to Weeks’s house; a neighbor told them where he kept his key, and the officers entered his house. They searched Weeks’s room and seized evidence. They turned this evidence over to a United States marshal. Later that same day, the officers returned with the marshal to search for more evidence. The door was answered by a boarder, and the marshal searched Weeks’s room again, this time seizing various papers and envelopes. Neither the officers nor the marshal had obtained a search warrant. These articles were provided to the district attorney and were offered as evidence against Weeks at his trial. Just before trial, Weeks filed a petition arguing that this property had been seized in violation of the Missouri and the United States Constitutions. He urged the court to order that this property be returned. The trial court ordered the return of all property unrelated to the charges, but it denied his request as to property pertinent to the crimes charged. At trial, Weeks again moved the court to return his property, and again it denied the motion.
The case was eventually appealed to the United States Supreme Court, which delivered an opinion authored by Justice Day. It set out to analyze the case under the Fourth Amendment’s guarantee against unreasonable searches and seizures. The Court recited the history of the amendment and its attendant jurisprudence, relying on the 1886 case of Boyd v. United States, 116 U.S. 616 (1886). The Court stated that the purpose and effect of the Fourth Amendment is to limit and restrain courts and federal officials from exercising power and authority in violation of its edict: to secure the people, their persons, houses, papers, and effects against unreasonable searches and seizures under the guise of law. The Court noted that this protection extends to all, whether accused of a crime or not, and that courts should not support any tendency of officers and officials to obtain convictions by means of unlawful seizures and forced confessions.
The Court then set out the issue in this case by stating that this case is not an assertion by the government of a right “to search the person of the accused when legally arrested to discover and seize the fruits or evidences of crime.” Nor is it a case concerning the admissibility of evidence found upon a person and within his control at his otherwise lawful arrest. Rather, the Court held, this case involves the right of a court to retain as evidence the letters and personal correspondence of the accused, seized in his house in his absence and without his authority, by a marshal without a warrant for the search or for the arrest. The Court held that if evidence could be seized and held in this manner and used against the accused, then the protection of the Fourth Amendment was of no value and may as well be stricken from the Constitution. The efforts of courts, officers, and officials to bring criminals to justice are praiseworthy. These efforts may not, however, sacrifice the fundamental laws of the country in doing so. Here, a warrant was necessary, and the invasion of the sanctity of Weeks’s home under these circumstances violated Weeks’s most basic constitutional rights. Because the evidence used against Weeks would not have come into the possession of the district attorney but for the unlawful search and seizure, the Court reversed the decision and remanded the case for proceedings in accord with its opinion.