Kremen v. United States
Headline: Reverses convictions after finding FBI’s warrantless seizure and removal of an entire cabin’s contents unlawful, blocking key house evidence and ordering new trials for the accused.
Holding: The Court reversed the defendants’ convictions and ordered new trials because FBI agents seized and removed the cabin’s entire contents without a search warrant, and some of those house items were used at trial.
- Reverses convictions and orders new trials when house evidence is seized without a warrant.
- Bars use at trial of an entire dwelling’s contents taken and removed without judicial approval.
- Affects federal agents’ procedures for searching and seizing private homes.
Summary
Background
FBI agents found two men who were fugitives, Thompson and Steinberg, together with three other people at a secluded cabin near Twain Harte, California. The agents watched the cabin for about 24 hours and then arrested the two fugitives and three companions. The agents had arrest warrants for the two fugitives but no warrants for the three companions. The agents searched the four people and seized documents from their persons. They also made an exhaustive search of the cabin, seized the entire contents, and took that property about two hundred miles to the FBI office in San Francisco for examination. The three accused were convicted of helping the fugitives and of related conspiracy charges, and the convictions were affirmed on appeal before the case reached this Court.
Reasoning
The single controlling issue the Court decided was whether the search and seizure by the FBI were lawful. A majority concluded that taking the entire contents of the house and removing those items for later examination was beyond what the Court’s cases allow. The Court said that although items taken from the defendants’ persons might have been admissible, the admission of some house items seized in that broad, warrantless way made the guilty verdicts illegal. Because of that error, the Court reversed the convictions and instructed that the defendants be given new trials.
Real world impact
The ruling prevents prosecutors from relying on house materials seized and removed without a search warrant in these prosecutions. It affects how federal agents handle searches of dwellings and how trial courts treat evidence taken from a home without prior judicial approval. The reversal is immediate for these defendants and requires retrials.
Dissents or concurrances
Two Justices dissented, saying each seized item’s legality depends on its own circumstances and any error should be treated under harmless-error rules because other evidence supported guilt.
Opinions in this case:
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