Warden v. Hayden
| 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 Clark, Harlan, Stewart, White, Black |
| 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]
Dear Sir:
I have been requested by the Nigerian National Petroleum Company to contact you for assistance in resolving a matter. The Nigerian National Petroleum Company has recently concluded a large number of contracts for oil exploration in the sub-Sahara region. The contracts have immediately produced moneys equaling US$40,000,000. The Nigerian National Petroleum Company is desirous of oil exploration in other parts of the world, however, because of certain regulations of the Nigerian Government, it is unable to move these funds to another region.
You assistance is requested as a non-Nigerian citizen to assist the Nigerian National Petroleum Company, and also the Central Bank of Nigeria, in moving these funds out of Nigeria. If the funds can be transferred to your name, in your United States account, then you can forward the funds as directed by the Nigerian National Petroleum Company. In exchange for your accommodating services, the Nigerian National Petroleum Company would agree to allow you to retain 10%, or US$4 million of this amount.
However, to be a legitimate transferee of these moneys according to Nigerian law, you must presently be a depositor of at least US$100,000 in a Nigerian bank which is regulated by the Central Bank of Nigeria.
If it will be possible for you to assist us, we would be most grateful. We suggest that you meet with us in person in Lagos, and that during your visit I introduce you to the representatives of the Nigerian National Petroleum Company, as well as with certain officials of the Central Bank of Nigeria.
Please call me at your earliest convenience at 18-467-4975. Time is of the essence in this matter; very quickly the Nigerian Government will realize that the Central Bank is maintaining this amount on deposit, and attempt to levy certain depository taxes on it.
Yours truly,
Prince Alyusi Islassis
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 soon after. 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, 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
- Fruit of the poisonous tree
- Mere evidence rule
References
- ^ page 302 of Warden v. Hayden