Carroll v. United States

Background

A group of men arrested in Washington, D.C., for running a local lottery asked a judge to suppress evidence taken from their persons at arrest, arguing the arrest warrants lacked probable cause. The District Court granted those suppression motions. The Government appealed to the local Court of Appeals, which reversed and said the Government could appeal such suppression orders. The Supreme Court accepted review only on the narrow question whether the Government may take that immediate appeal.

Reasoning

The Court asked whether a judge’s pretrial order to suppress evidence, entered after indictment in the trial court, is the kind of final decision the Government can appeal. Looking at the long history of federal criminal appeals and the governing statutes, the Court held that appeals by the Government are strictly limited by Congress. A suppression order made while a criminal prosecution is pending in the same district is interlocutory (not a final decision) and ordinarily not appealable. The Court also rejected the argument that special District of Columbia rules allowed the Government to appeal in this posture. The Court reversed the Court of Appeals and sent the case back for further proceedings consistent with that rule.

Real world impact

As a practical matter, prosecutors cannot immediately appeal many pretrial rulings that exclude evidence when those rulings are made after indictment in the trial court. The decision keeps evidence disputes for resolution in the trial court unless Congress creates a specific appellate route. The Court emphasized that if broader Government review is needed, it is for Congress to provide it.