Brief Fact Summary. Certain documents were requested by the government in connection with a proceeding regarding fraud to avoid paying duties on certain items.
Synopsis of Rule of Law. The Fourth Amendment of the United States Constitution (“Constitution”) protects against the invasion into a person’s private matters and will not allow the government to compel a person to produce private papers through subpoena.
Issue. Whether a compulsory production of a person’s private papers to be used in evidence against him in a judicial proceeding is an unreasonable search and seizure within the meaning of the Fourth Amendment of the Constitution?
Held. There need not be a physical invasion of one’s home to constitute a violation of the Fourth Amendment protection against unreasonable search and seizure. The Fourth Amendment of the Constitution protects against the invasion into a person’s private matters. This extends to the compulsory production of a person’s papers.
Concurrence. Justice Samuel F. Miller (“J. Miller”) would have held that this was a violation of the Fifth Amendment of the Constitution rather than the Fourth Amendment of the Constitution because, J. Miller argues, this is a criminal proceeding according to the language of the Fifth Amendment of the Constitution.
The seizure of stolen goods is authorized by the common law; and the seizure of goods forfeited for a breach of the revenue laws, or concealed to avoid the duties payable on them, has been authorized by English statutes for at least two centuries past;† and the like seizures have been authorized by our own revenue acts from the commencement of the government.View Full Point of Law