Board of License Comm'rs of Tiverton v. Pastore
Headline: Court dismisses challenge about using illegally seized evidence in liquor-license revocations as moot, leaving states and agencies free to decide whether such evidence can be admitted.
Holding: The Court dismissed the case as moot and refused to decide whether illegally obtained evidence may be used in civil liquor-license revocation hearings because the affected bar had gone out of business.
- No national ruling on admitting illegally obtained evidence in liquor-license hearings.
- Leaves state liquor boards and courts free to set their own rules.
- Case was dismissed because the affected bar went out of business, making it moot.
Summary
Background
A local liquor-serving business called the Attic Lounge faced a state board that sought to revoke its liquor license after a search produced evidence used at the board hearing. In a related criminal case a state judge ruled the search violated the Fourth Amendment. The bar argued that unlawfully obtained evidence could not be used in the civil license revocation proceeding. The Rhode Island Supreme Court held the exclusionary rule applies in such hearings, and the U.S. Supreme Court agreed to review the question.
Reasoning
After briefing and oral argument, the Court learned the Attic Lounge had gone out of business and counsel said no decision could now affect its license. The Justices explained that speculative or remote possibilities cannot keep a case alive and that a concrete, ongoing dispute is required. Because there was no longer a live controversy, the Court declined to decide the substantive question about admitting illegally obtained evidence and dismissed the writ of certiorari as moot.
Real world impact
Because the Court dismissed the case as moot, it did not resolve the split among states over whether illegally seized evidence may be used in civil liquor-license revocation hearings. State agencies and lower courts remain free to decide the issue under their own laws, and the question remains unresolved nationally. The Court also reminded lawyers they must promptly inform the Court of later developments that could end a dispute.
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