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Silverthorne Lumber Co. v. United States – Case Brief
Mr. Justice HOLMES delivered the opinion of the Court.
An indictment upon a single specific charge having been brought against the two Silverthornes mentioned, they both were arrested at their homes early in the morning of February 25, and were detained in custody a number of hours. While they were thus detained representatives of the Department of Justice and the United States marshal without a shadow of authority went to the office of their company and made a clean sweep of all the books, papers and documents found there. All the employees were taken or directed to go to the office of the District Attorney of the United States to which also the books, &c., were taken at once. Photographs and copies of material papers were made and a new indictment was framed based upon the knowledge thus obtained. The District Court ordered a return of the originals but impounded the photographs and copies. Subpoenas to produce the originals then were served and on the refusal of the plaintiffs in error to produce them the Court made an order that the subpoenas should be complied with, although it had found that all the papers had been seized in violation of the parties' constitutional rights. The refusal to obey this order is the contempt alleged.
Whether the warrantless search and seizure of the offices of the respondents violate their 4th amend. rights against unreasonable search and seizure?
District Court fined $250.00 and imprisoned Silverthorne for contempt of court. Failure to produce document for which a subpoena issued.
The Court ruled it violated the Silverthorne Lumber Co. 4th amend. rights.
Rationale: The essence of a provision forbidding the acquisition of evidence in a certain way is that not merely evidence so acquired shall not be used before the Court but that it shall not be used at all. Of course this does not mean that the facts thus obtained become sacred and inaccessible. If knowledge of them is gained from an independent source they may be proved like any others, but the knowledge gained by the Government's own wrong cannot be used by it in the way proposed
“Fruit of the poisonous tree” doctrine. The fruit of the poisonous tree doctrine prohibits the government from using evidence derived from conduct that violated the Fourth Amendment or other provisions of the constitution. Thus, the exclusionary rule remedy applies not only to the direct fruits (evidence) obtained by unconstitutional means, but also to all other evidence subsequently derived from it. The court found this rule was needed because without it the court feared the violation of constitutional rights would be encouraged, i.e., the police could violate the Fourth Amendment in anticipation of developing subsequent evidence that could be admitted at trial. If this was permitted it would defeat the purpose of the individuals’ rights as well as the exclusionary rule.