Weeks v. United States

Following is the case brief for Weeks v. United States, 232 U.S. 383 (1914)

Case Summary of Weeks v. United States:

  • Police officers arrested the defendant, Weeks, at his place of work.  Police officers then went to Weeks’ home, gained entry, and took possession of papers and other articles belonging to Weeks.
  • The police did not have a search warrant for Weeks’ home.
  • The evidence taken from Weeks’ home was later used against him at trial to convict him of transporting lottery tickets through the mail.
  • Weeks sought return of his property and argued that the search and seizure of his property violated the Fourth and Fifth Amendments to the Constitution.
  • The U.S. Supreme Court held that the police did violate Weeks’ Fourth Amendment rights, and reversed and remanded the case.

Weeks v. United States Case Brief

Statement of the Facts:

Police officers arrested Weeks without a warrant at Weeks’ place of work.  At the same time, other police officers went to Weeks’ home and gained entry because a neighbor told the police the location of his house key.  Once in Weeks’ home, the officers searched the home and seized papers and other property belonging to Weeks.  Later that same day a U.S. Marshal conducted another search of Weeks’ home and seized additional evidence.

The evidence was used against Weeks at trial.  Weeks was convicted of using the mails to transport lottery tickets.  Before and at trial, Weeks demanded that his property be given back to him and argued that the police search and seizure was a violation of his Fourth and Fifth Amendment rights under the Constitution such that the evidence could not be used at trial.

The trial court allowed some of Weeks’ property to be returned to him, but denied Weeks’ request as to the evidence that supported his conviction.

Procedural History:

  • The trial court, the Western District Court of Mississippi, denied Weeks’ constitutional challenge to the evidence seized, and only allowed the property that was not relevant to the trial to be given back to Weeks.
  • The case came before the U.S. Supreme Court on writ of error.

Issue and Holding:

Did the search of Weeks’ home and the seizure of his papers and other property violate the Fourth Amendment of the Constitution?  Yes.

Judgment:

The Western District Court of Mississippi decision is reversed and remanded.

Rule of Law or Legal Principle Applied:

The Fourth Amendment protects people from having their homes searched and items seized without a warrant.

Reasoning:

The Fourth Amendment supports the principle that “a man’s home is his castle.”  Therefore, invasion of a person’s home by the government without a warrant is not permitted.  In fact, throughout history, beginning in England and through the drafting of the Constitution, the notion that “a man’s home is his castle” has been jealously guarded.

Further, the government’s zeal in trying to track down criminals does not justify an unreasonable, warrantless search and seizure in someone’s home.  If letters and private documents can be seized and held as evidence against someone without a warrant, then the Fourth Amendment has no meaning.  Accordingly, the District Court was wrong to deny Weeks’ request to have his personal documents returned to him.

Significance:

Weeks v. United States is the first case that introduced the concept of what we now call the “exclusionary rule.”  While the Court’s opinion does not expressly state it, the opinion implies that the evidence seized in violation of the Fourth Amendment should not have been used against the accused in this case.

Student Resources:

Read the Court’s Full Opinion

 

 

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