United States v. Payner (original) (raw)

dbo:abstract

United States v. Payner, 447 U.S. 727 (1980), is a United States Supreme Court case in which the Court reversed a district court's suppression of evidence in the criminal prosecution of an Ohio businessman charged with tax evasion. The case concerned both issues of criminal procedure and the application of the exclusionary rule derived from the Fourth Amendment. By a 6–3 margin the Court both reaffirmed its earlier rulings' holding that only the party whose Fourth Amendment protections may have been violated has standing to challenge the evidence seized in the search, and barred lower courts from exercising their supervisory power to exclude such evidence at the trial of third parties. The case had been brought as the fruit of Operation Trade Winds, a lengthy Internal Revenue Service (IRS) investigation into the use of offshore accounts in tax havens by American citizens attempting to evade tax liability and hide assets, some of which were believed to have been derived from criminal activities. At one point, a private investigator working with a Florida IRS agent had taken the executive's briefcase for the IRS to open and duplicate the documents within, then returned the briefcase. (This aspect was described by the district judge as the "briefcase caper", a sobriquet which has subsequently become attached to the case as a whole). Subpoenas based on the information in those documents yielded the documents used in a prosecution later of Ohio businessman Jack Payner. Lewis Powell wrote for the majority that prior case law gave Payner no reasonable expectation of privacy in the documents used to build the case against him. While the Court, too, was outraged by the IRS agent's disregard for the law, the judicial branch's supervisory power was meant to be used only against its own excesses, and Congress was better equipped to remedy such breaches of the Constitution since there were no ways to limit how a court might apply such a rule. Thurgood Marshall's dissent noted not only the extent to which the IRS had gone in planning the briefcase caper but that its agents had purposely been instructed to take advantage of the loophole created by the court's standing rule. Later commentators read the case as expanding the standing rule, and indicating a shift to focusing on the deterrence effect of applying the exclusionary rule instead of the courts' supervisory role. (en)

dbo:wikiPageExternalLink

dbo:wikiPageID

30979860 (xsd:integer)

dbo:wikiPageLength

41597 (xsd:nonNegativeInteger)

dbo:wikiPageRevisionID

1075782145 (xsd:integer)

dbo:wikiPageWikiLink

dbp:arguedate

0001-02-20 (xsd:gMonthDay)

dbp:argueyear

1980 (xsd:integer)

dbp:case

United States v. Payner, (en)

dbp:concurrence

Burger (en)

dbp:courtlistener

https://www.courtlistener.com/opinion/110317/united-states-v-payner/

dbp:decidedate

0001-06-23 (xsd:gMonthDay)

dbp:decideyear

1980 (xsd:integer)

dbp:dissent

Marshall (en)

dbp:findlaw

https://caselaw.findlaw.com/us-supreme-court/447/727.html

dbp:fullname

United States v. Jack Payner (en)

dbp:googlescholar

https://scholar.google.com/scholar_case%3Fcase=5827713761582890953

dbp:holding

Defendant convicted of tax evasion did not have standing to challenge constitutionality of evidence resulting from unlawful investigative techniques that targeted others; supervisory power of the federal courts does not authorize a court to suppress otherwise admissible evidence on the ground that it was seized unlawfully from a third party not before the court. Sixth Circuit reversed. (en)

dbp:joindissent

Brennan, Blackmun (en)

dbp:joinmajority

Burger, Stewart, White, Rehnquist, Stevens (en)

dbp:justia

http://supreme.justia.com/us/447/727/

dbp:lawsapplied

dbr:Fourth_Amendment_to_the_United_States_Constitution

dbp:litigants

United States v. Payner (en)

dbp:loc

http://cdn.loc.gov/service/ll/usrep/usrep447/usrep447727/usrep447727.pdf

dbp:majority

Powell (en)

dbp:oralargument

https://www.oyez.org/cases/1970-1979/1979/1979_78_1729/argument/

dbp:oyez

https://www.oyez.org/cases/1979/78-1729

dbp:parallelcitations

172800.0

dbp:prior

17280.0

dbp:subsequent

17280.0

dbp:uspage

727 (xsd:integer)

dbp:usvol

447 (xsd:integer)

dbp:wikiPageUsesTemplate

dcterms:subject

rdf:type

rdfs:comment

United States v. Payner, 447 U.S. 727 (1980), is a United States Supreme Court case in which the Court reversed a district court's suppression of evidence in the criminal prosecution of an Ohio businessman charged with tax evasion. The case concerned both issues of criminal procedure and the application of the exclusionary rule derived from the Fourth Amendment. By a 6–3 margin the Court both reaffirmed its earlier rulings' holding that only the party whose Fourth Amendment protections may have been violated has standing to challenge the evidence seized in the search, and barred lower courts from exercising their supervisory power to exclude such evidence at the trial of third parties. (en)

rdfs:label

United States v. Payner (en)

owl:sameAs

prov:wasDerivedFrom

wikipedia-en:United_States_v._Payner?oldid=1075782145&ns=0

foaf:isPrimaryTopicOf

wikipedia-en:United_States_v._Payner

foaf:name

(en)
United States v. Jack Payner (en)

is dbo:wikiPageRedirects of

is dbo:wikiPageWikiLink of

is foaf:primaryTopic of

wikipedia-en:United_States_v._Payner