Warden v. Hayden: Difference between revisions
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'''''Warden v. Hayden''''', {{ussc|387|294|1967}}, was a [[Supreme Court of the United States|United States Supreme Court]] case that held that 'mere evidence' may be seized and held as [[evidence (law)|evidence]] in a trial. This finding reversed previous Supreme Court decisions such as [[ |
'''''Warden v. Hayden''''', {{ussc|387|294|1967}}, was a [[Supreme Court of the United States|United States Supreme Court]] case that held that 'mere evidence' may be seized and held as [[evidence (law)|evidence]] in a trial. This finding reversed previous Supreme Court decisions such as [[Boyd v. United States]] 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...''<ref>page 302 of Warden v. Hayden</ref> |
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==Background of the case== |
==Background of the case== |
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Revision as of 00:36, 20 January 2010
| Warden v. Hayden | |
|---|---|
 | |
| Argued April 12, 1967 Decided May 29, 1967 | |
| Full case name | Warden, Maryland Penitentiary v. Hayden |
| Citations | 387 U.S. 294 (more) |
| Case history | |
| Prior | Defendant convicted; conviction reversed on appeal, (87 S. Ct. 1642) |
| Subsequent | Conviction upheld |
| Holding | |
| Items of 'evidentiary value only' are lawfully subject to seizure | |
| Court membership | |
| |
| Case opinions | |
| Majority | Brennan, joined by Black, Clark, Douglas, Harlan, Stewart, White |
| Concurrence | Fortas, joined by Warren |
| Dissent | Douglas |
| Laws applied | |
| U.S. Const. amend. IV | |
Warden v. Hayden, 387 U.S. 294 (1967), was a United States Supreme Court case that held that 'mere evidence' may be seized and held as evidence in a trial. This finding reversed previous Supreme Court decisions such as Boyd v. United States 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...[1]
Background of the case
In the morning of March 17, 1962, the Diamond Cab Company in Baltimore, Maryland was robbed by an armed man. Two cab drivers followed the man to a house and dispatchers relayed the information to police. The police arrived in minutes. As officers knocked on the door and announced themselves. When Mrs Hayden answered the door, they stated that a robber had entered the house and asked to search the house. She allowed them in. As officers searched the house, they found the gun and in a washing machine, they found clothing that matched the description of the armed man that had been reported by the cab company. Weapons were found concealed in a bathroom (in the toilet flush tank) that matched the description of those used by the robber, and ammunition for the shotgun was found in the bureau in Mr Hayden's bedroom, and ammunition for the handgun under his mattress.
Mr Hayden was convicted at a bench trial. During appeals, 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 appeals 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 immediate 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
References
- ^ page 302 of Warden v. Hayden