''Warden v. Hayden'', 387 U.S. 294 (1967), was a
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case that held that 'mere evidence' may be seized and held as
evidence
Evidence for a proposition is what supports this proposition. It is usually understood as an indication that the supported proposition is true. What role evidence plays and how it is conceived varies from field to field.
In epistemology, evidenc ...
in a trial, allowing such evidence obtained in a search to be used. This finding reversed previous Supreme Court decisions such as ''
Boyd v. United States
''Boyd v. United States'', 116 U.S. 616 (1886) was a decision by the United States Supreme Court in which the Court held that "a search and seizure asequivalent oa compulsory production of a man's private papers" and that the search was "an 'un ...
'' which had held that search warrants ''may not be used as a means of gaining access to a man's house or office and papers solely for the purpose of making search to secure evidence to be used against him in a criminal or penal proceeding...''
[.]
Background of the case
In the morning of March 17, 1962, an armed man robbed the Diamond Cab Company in Baltimore, Maryland. Two cab drivers followed the man to a house and relayed the information to the police, who arrived quickly. After the police knocked on the door and announced that they were searching for a robber seen entering the house, Mrs. Hayden consented to the search. A search of the premises revealed a gun and clothing, found in a washing machine, that matched the description of the armed man that had been reported by the cab company. Weapons were found in a bathroom that matched the description of those used by the robber. Ammunition for the shotgun was found in Mr. Hayden's chest of drawers and ammunition for the handgun under his mattress.
Hayden was convicted at a
bench trial. During
appeals
In law, an appeal is the process in which cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and ...
, courts held that the search of the house was valid; the search for weapons that were used in the crime, or could be used against the police was also valid. However, the appellate court held that the clothing was of 'mere evidential' nature, not in plain sight, and this was not properly seized. The police had been in
hot pursuit of the robber, and thus were exempt from needing a warrant to search the house. However, under the rules at that time, seizing evidence such as the clothing that fit the description of the fleeing robber would not have been allowed. Suppressing the improperly seized evidence would lead to a new trial under the principle of the
fruit of the poisonous tree.
See also
*
List of United States Supreme Court cases, volume 387
This is a list of all the United States Supreme Court cases from volume 387 of the ''United States Reports
The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
*
Fruit of the poisonous tree
*
Mere evidence rule
References
External links
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{{US4thAmendment, warrantexceptions, state=expanded
United States Supreme Court cases
United States Supreme Court cases of the Warren Court
United States Fourth Amendment case law
1967 in United States case law