Warden, Md. Penitentiary v. Hayden
Encyclopedia
Warden v. Hayden, , 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...
Mr 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 immediate 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
.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case that held that 'mere evidence' may be seized and held as evidence
Evidence (law)
The law of evidence encompasses the rules and legal principles that govern the proof of facts in a legal proceeding. These rules determine what evidence can be considered by the trier of fact in reaching its decision and, sometimes, the weight that may be given to that evidence...
in a trial. This finding reversed previous Supreme Court decisions such as Boyd v. United States
Boyd v. United States
Boyd v. United States, , was a decision by the United States Supreme Court, which held that “a search and seizure [was] equivalent [to] a compulsory production of a man's private papers” and that the search was “an 'unreasonable search and seizure' within the meaning of the Fourth Amendment.”In the...
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...
Background of the case
In the morning of March 17, 1962, the Diamond Cab Company in Baltimore, Maryland was robbed by an armed man. Two cab drivers followed the man to a house and dispatchers relayed the information to police. The police arrived in soon after, knocked on the door, and announced themselves. When Mrs Hayden answered the door, they stated that a robber had entered the house and asked to conduct a search. She allowed them in. 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.Mr Hayden was convicted at a bench trial
Bench trial
A bench trial is a trial held before a judge sitting without a jury. The term is chiefly used in common law jurisdictions to describe exceptions from jury trial, as most other legal systems do not use juries to any great extent....
. 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 immediate pursuit
Immediate pursuit
Immediate pursuit is a common law principle describing rules of engagement to enter into combat with or apprehend and forcibly detain another, invade one's privacy, etc. Immediate pursuit enables, for example, a citizen to arrest a person committing some offence, without incurring legal liability...
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
Fruit of the poisonous tree
Fruit of the poisonous tree is a legal metaphor in the United States used to describe evidence that is obtained illegally. The logic of the terminology is that if the source of the evidence is tainted, then anything gained from it is as well.Such evidence is not generally admissible in court...
.
See also
- List of United States Supreme Court cases, volume 387
- Fruit of the poisonous treeFruit of the poisonous treeFruit of the poisonous tree is a legal metaphor in the United States used to describe evidence that is obtained illegally. The logic of the terminology is that if the source of the evidence is tainted, then anything gained from it is as well.Such evidence is not generally admissible in court...
- Mere evidence ruleMere evidence ruleIn the law of the United States, the mere evidence rule was a historical doctrine that defined the scope of the Fourth Amendment to the United States Constitution.-Origins:...