Olmstead v. United States

The Case: U.S. Supreme Court’s ruling on the application of the Fourth and Fifth Amendments to wiretapping private telephone conversations

Date: Decided on June 4, 1928

The Supreme Court’s ruling in Olmstead v. United States held that the Fourth Amendment guarantee against unreasonable searches and seizure did not apply to the government’s wiretapping of private telephone conversations. The Court also ruled that since the Fourth Amendment had not been violated, the Fifth Amendment protection against self-incrimination could not apply.

Roy Olmstead, the suspected ringleader of an extensive bootlegging operation, was convicted of conspiring with about fifty other people to unlawfully import, possess, transport, and sell alcohol in violation of the National Prohibition Act. Federal officers gathered incriminating information against the defendants via wiretaps from the streets near the defendants’ homes and in the basement of Olmstead’s office. The placement of the wiretaps did not involve physical entry onto the defendants’ property. Olmstead challenged the conviction on the grounds that the wiretapped private telephone conversations recorded by federal officers without a warrant had been admitted in his criminal trial in violation of his Fourth and Fifth Amendment rights. The Ninth Circuit Court of Appeals upheld Olmstead’s conviction, and he appealed to the U.S. Supreme Court.

In Olmstead v. United States, the specific issue before the Court was whether the introduction into evidence of private telephone conversations intercepted by means of a wiretap violated the defendant’s Fourth and Fifth Amendment rights. By a vote of five to four, the Court held that listening to communications passing over telephone wires did not constitute a search or seizure under the Fourth Amendment, because the evidence was simply a conversation and no physical entry of the defendants’ houses or offices had taken place. In upholding Olmstead’s conviction, the Court reasoned that the Fourth Amendment prohibition against unreasonable searches and seizures only applied to material things such as persons, houses, and papers, and did not apply to voluntary conversations that were overhead. The Court further held that since the Fourth Amendment did not apply, the Fifth Amendment argument had to be dismissed.

Impact

The Olmstead decision was the first case to consider the legality of wiretaps. The Communications Act of 1934 made unauthorized wiretapping a federal crime. Nevertheless, the federal law did little to deter wiretapping and eavesdropping by government officials. The Olmstead decision was overturned in Katz v. United States in 1967, whereby the U.S. Supreme Court held that the Fourth Amendment applied to eavesdropping, including wiretapping, even when it occurs without physical entry, because the amendment protects people’s right to privacy anytime there is a reasonable expectation of privacy.

Bibliography

Charns, Alexander. Cloak and Gavel: FBI Wiretaps, Bugs, Informers, and the Supreme Court. Urbana: University of Illinois Press, 1992.

Kuhn, Betsy. Prying Eyes: Privacy in the Twenty-First Century. Minneapolis, Minn.: Twenty-First Century Books, 2008.