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Wolf v. Colorado
Citations: 93 L. Ed. 2d 1782; 69 S. Ct. 1359; 338 U.S. 25; 1949 U.S. LEXIS 2079; 93 L. Ed. 1782Docket: 17 and 18
Court: Supreme Court of the United States; June 27, 1949; Federal Supreme Court; Federal Appellate Court
A State court conviction does not violate the 'due process of law' under the Fourteenth Amendment solely because evidence admitted at trial would be inadmissible in federal court under the Fourth Amendment, as established in Weeks v. United States. The Colorado Supreme Court upheld such convictions, which were brought before the U.S. Supreme Court for review. Unlike the Bill of Rights, the Fourteenth Amendment does not impose specific limitations on state criminal justice systems. The Court has consistently rejected the idea that the Due Process Clause incorporates the Bill of Rights, reaffirming this stance in multiple cases, including Adamson v. California. The Due Process Clause requires states to uphold fundamental rights inherent to ordered liberty, which are not fixed but evolve with societal standards. This living principle of due process does not lend itself to rigid definitions but rather requires a dynamic interpretation through a gradual process of inclusion and exclusion. The judiciary's task is to adapt and define the contours of fundamental rights as society progresses. The Fourth Amendment protects individuals from arbitrary police intrusion, forming a foundational element of a free society and enforceable against the States via the Due Process Clause. An unlawful police search, initiated without legal authority, contradicts the principles of human rights reflected in constitutional history. If a State were to permit such intrusions, it would violate the Fourteenth Amendment. However, the enforcement and remedies for this right are complex and not subject to rigid solutions. The Supreme Court's decision in Weeks v. United States established that evidence obtained through illegal search and seizure is inadmissible in federal prosecutions, a principle derived from judicial interpretation rather than explicit constitutional mandate. Over time, there has been significant variation among states regarding the exclusion of such evidence; prior to Weeks, 27 states had addressed the issue, with 26 opposing its exclusion. Since the decision, 31 states have rejected the Weeks doctrine, while 16 have accepted it. Importantly, jurisdictions outside the U.S., including the UK and Commonwealth nations, have not deemed evidence from illegal searches inadmissible, indicating that privacy rights can be safeguarded through other means beyond the exclusionary rule, which primarily benefits those directly affected by incriminating evidence found unlawfully. Remanding individuals who are not harmed by searches to private action remedies and police internal discipline does not violate basic standards. While excluding evidence can deter unreasonable searches, it is not the Court's role to deem a state's reliance on other enforcement methods as inadequate under the Due Process Clause. The opinion of former Justice Cardozo supports this view, noting the limited impact of federal oversight compared to community accountability for local police. Consequently, the Fourteenth Amendment does not prohibit the admission of evidence obtained through unreasonable searches in state court prosecutions. Although the Fourth Amendment forbids such admissions, a congressional statute could change this dynamic. Additionally, if Congress attempted to enforce the Weeks doctrine on states, it would raise questions about the deference owed to legislative judgments on this issue. The document also includes a list of states that opposed the Weeks doctrine prior to its decision. Table B identifies Iowa as the only state to formulate the Weeks Doctrine prior to the Weeks decision. Table C notes that every state except Rhode Island has addressed the Weeks Doctrine post-decision, with Rhode Island's State v. Lorenzo ruling that evidence was admissible due to lack of a timely motion to suppress, regardless of the application of federal rules. Table D lists states that first addressed the Weeks Doctrine after the decision and accepted it, including Florida (Atz v. Andrews), Indiana (Flum v. State), Kentucky (Youman v. Commonwealth), Mississippi (Tucker v. State), Wisconsin (Hoyer v. State), and Wyoming (State v. George). Table E outlines states that rejected the Weeks Doctrine for the first time post-decision, including Arizona (Argetakis v. State), California (People v. Mayen), Colorado (Massantonio v. People), Delaware (State v. Chuchola), Louisiana (State v. Fleckinger), Nevada (State v. Chin Gim), New Jersey (State v. Black), New Mexico (State v. Dillon), North Dakota (State v. Fahn), Ohio (State v. Lindway), Pennsylvania (Commonwealth v. Dabbierio), Texas (Welchek v. State), Utah (State v. Aime), and Virginia (Hall v. Commonwealth). Notably, Texas amended its statute in 1925 to exclude evidence obtained in violation of constitutional provisions. Table F details states that overruled or distinguished prior decisions contrary to the Weeks Doctrine after the decision. Idaho initially refused to follow the Weeks decision in State v. Myers but later adopted the federal rule in State v. Arregui. Illinois, Michigan, Missouri, Montana, Oklahoma, South Dakota, Tennessee, Washington, and West Virginia also adopted or distinguished the federal rule in subsequent cases. States that reviewed prior decisions post-Weeks and maintained those decisions include Alabama, Arkansas, Connecticut, Georgia, Kansas, Maine, Maryland, Massachusetts, Minnesota, Nebraska, New Hampshire, New York, North Carolina, Oregon, South Carolina, and Vermont. Notably, Iowa has repudiated its previous interpretation of the Weeks doctrine. A summary of the current stance on the Weeks doctrine reveals that several states, including Alabama, Arizona, and California, reject it, while states like Florida, Idaho, and Illinois are in agreement with it. Additionally, jurisdictions in the United Kingdom and the British Commonwealth, such as Australia, Canada, England, and India, have accepted evidence obtained through illegal search and seizure. Common law allows for legal actions against officers conducting illegal searches, including claims for damages against the officer, those who maliciously procure warrants, magistrates acting without jurisdiction, and others assisting in unlawful searches. Statutory provisions exist to punish those who maliciously obtain search warrants or exceed their authority, with specific statutes cited from various states. Some jurisdictions impose civil remedies for unlawful searches, while others penalize the issuance of general or unsupported warrants. The passage concludes that evidence obtained through trespass may not be excluded from proceedings, despite arguments suggesting otherwise. This stance acknowledges historical precedents, balancing individual privacy rights with societal needs for law enforcement. The text references key cases and legal principles that have shaped these doctrines, emphasizing the need to weigh competing interests in the justice system.