Harris v. United States
"Harris v. United States" is a significant legal case concerning the Fourth Amendment's protections against unlawful search and seizure. The case arose when James H. Harris was convicted of robbery, with evidence against him including an automobile registration card found in his car after it was impounded by police. Harris contested the admissibility of this evidence, arguing it was obtained through an illegal search. Initially, a panel of the Court of Appeals reversed his conviction, but this decision was later overturned when the full court upheld the conviction, asserting that the evidence was lawfully obtained.
The U.S. Supreme Court ultimately affirmed this ruling, emphasizing the "plain view" doctrine, which allows law enforcement to seize evidence that is clearly visible while they are legally present in a location. This decision highlighted a growing trend in the Court's approach to balance the rights of criminal suspects with the needs of law enforcement. Critics of the ruling express concern that it may weaken Fourth Amendment protections, particularly regarding searches conducted while a suspect's property is in police custody. Overall, the case illustrates ongoing debates about privacy rights and police powers within the American legal framework.
Harris v. United States
The Case: U.S. Supreme Court ruling on search and seizure
Date: Decided on March 5, 1968
Significance: This case established the principle that if evidence of crimes is in “plain view” of law-enforcement officers while the officers are fulfilling their authorized duties, its use in criminal proceedings does not violate a defendant’s constitutional protection against unlawful search and seizure.
James H. Harris, the petitioner, prior to his appeal to the U.S. Supreme Court, was tried for robbery in the U.S. District Court for the District of Columbia. Evidence used against him included his victim’s automobile registration card, which the police found on the metal strip under the door of Harris’s car after it had been impounded for its protection while Harris was being held as the robbery suspect. During his trial, Harris moved to have that evidence suppressed on the grounds that it was obtained through unlawful search. The district court denied the request, and Harris was convicted and sentenced to prison. Thereafter, a panel of the Court of Appeals for the District of Columbia reversed the conviction, concluding that the registration card had been obtained by unlawful search; however, it also granted the government’s petition for a rehearing before the full court of appeals, which subsequently overturned the panel’s determination, ruling that the conviction did not violate the petitioner’s rights.
On certiorari, the U.S. Supreme Court upheld the decision, affirming the admissibility of the questionable evidence. Seven justices concurred in the majority opinion, arguing that nothing in the Fourth Amendment protects a suspect from the use of incriminating evidence found as a result of normal safeguards taken while a suspect’s property is in police custody. According to the opinion, objects in the “plain view” of police officers authorized to be in a position to view the objects cannot be construed as the products of a search, are therefore subject to seizure, and may be introduced as evidence.
Various Supreme Court cases, including Ker v. California (1963), had established the right of law-enforcement agents to seize objects in plain view to be used as criminal evidence, but none addressed the issue of whether securing of evidence from a defendant’s property while it was in police custody constituted an illegal search. Jurists concerned with the protection of an accused individual’s rights argue that the Harris decision erodes the Fourth Amendment guarantees against illegal search and seizure. Because the circumstances were somewhat unusual, however, the application of Harris to other attempts to suppress evidence is likely to be fairly limited. Nevertheless, the ruling does reflect the Supreme Court’s increasing unwillingness to broaden its interpretation of constitutional guarantees in favor of the accused to the disadvantage of criminal investigators and prosecutors.
Bibliography
Dash, Samuel. The Intruders: Unreasonable Searches and Seizures from King John to John Ashcroft. New Brunswick, N.J.: Rutgers University Press, 2004.
Del Carmen, Rolando V. Criminal Procedure: Law and Practice. 6th ed. Belmont, Calif.: Thomson/Wadsworth, 2004.
LaFave, W. R. Search and Seizure: A Treatise on the Fourth Amendment. 3d ed. St. Paul, Minn.: West Publishing, 1995.
McWhirter, Darien A. Search, Seizure, and Privacy. Phoenix, Ariz.: Oryx Press, 1994.