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752 KB
Extraction Summary
5
People
5
Organizations
0
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
752 KB
Summary
This legal document argues that a district court's supervisory authority to suppress evidence is limited and should only be used when there is a clear violation of constitutional, statutory, or procedural law. Citing multiple legal precedents, the author contends that this power must be 'sparingly exercised' and that the defendant in this case has not established such a violation, and is therefore not entitled to an evidentiary hearing to challenge the government's actions.
People (5)
| Name | Role | Context |
|---|---|---|
| Payner |
Party in the cited legal case 'Payner, 447 U.S. at 737'.
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| Anderson |
Party in the cited legal case 'United States v. Anderson, 772 F.3d 969, 976'.
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| Jennings |
Party in the cited legal case 'United States v. Jennings, 960 F.2d 1488, 1491'.
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| Lambus |
Party in the cited legal case 'Lambus, 897 F.3d at 401'.
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| Coke |
Party in the cited legal case 'Coke, 2011 WL 3738969, at *6'.
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Organizations (5)
| Name | Type | Context |
|---|---|---|
| Supreme Court | government agency |
Cited as establishing requirements for suppressing evidence.
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| Second Circuit | government agency |
Cited as establishing requirements for suppressing evidence.
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| 2d Cir. | government agency |
Court of appeals associated with the 'United States v. Anderson' case.
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| 9th Cir. | government agency |
Court of appeals associated with the 'United States v. Jennings' case.
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| Government | government agency |
The entity whose practices are being challenged and whose actions the defendant seeks to probe.
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Timeline (1 events)
Relationships (1)
The defendant
→
Adversarial
→
The Government
The document describes the defendant's legal argument against the Government, seeking to suppress evidence and probe the Government's actions.
Key Quotes (5)
"the supervisory power does not extend” to “disregard[ing] the considered limitations of the law it is charged with enforcing"Source
— Payner, 447 U.S. at 737
(A holding from a Supreme Court case limiting a district court's supervisory authority.)
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Quote #1
"Absent a violation of a recognized right under the Constitution, a statute, or a procedural rule, a district court is not entitled to exclude evidence as a sanction against government practices disapproved of by the court."Source
— United States v. Jennings, 960 F.2d 1488, 1491 (9th Cir. 1992)
(A quote from a 9th Circuit case establishing the conditions under which a district court can exclude evidence.)
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Quote #2
"sparingly exercised"Source
— Lambus, 897 F.3d at 401
(Describing how the supervisory power of a court should be used.)
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Quote #3
"We can appreciate the district court’s frustration at careless government representations that may impact the integrity of judicial decisions, especially proffers in support of ex parte applications that an adversary has no opportunity to dispute[,]"Source
— Lambus, 897 F.3d at 401-02
(A quote acknowledging a district court's frustration but ultimately finding it erred in suppressing evidence.)
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Quote #4
"has no Fourth Amendment right, and the novel substantive due process right he asks this Court to create cannot be described as a recognized right."Source
— Coke, 2011 WL 3738969, at *6
(A finding from a case where the court declined to exercise supervisory powers to suppress wiretap evidence.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,233 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 138 of 239
The law is clear that a district court’s supervisory authority does not extend to suppressing evidence absent some violation of the Constitution or other governing law. See Payner, 447 U.S. at 737 (holding that “the supervisory power does not extend” to “disregard[ing] the considered limitations of the law it is charged with enforcing”); United States v. Anderson, 772 F.3d 969, 976 (2d Cir. 2014) (same); United States v. Jennings, 960 F.2d 1488, 1491 (9th Cir. 1992) (“Absent a violation of a recognized right under the Constitution, a statute, or a procedural rule, a district court is not entitled to exclude evidence as a sanction against government practices disapproved of by the court.”). The requirements established by the Supreme Court and the Second Circuit for suppressing evidence would have little effect if district courts were free to disregard them and suppress evidence by invoking their supervisory authority. Consistent with that principle, and given that this power is “sparingly exercised,” Lambus, 897 F.3d at 401, (emphasis in original), this Court should not elect to do so here where the defendant has not established a violation of her Fourth Amendment, Fifth Amendment, or due process rights. See, e.g., id. at 401-02 (“We can appreciate the district court’s frustration at careless government representations that may impact the integrity of judicial decisions, especially proffers in support of ex parte applications that an adversary has no opportunity to dispute[,]” but finding that the district court erred in suppressing evidence by invoking its inherent authority); Coke, 2011 WL 3738969, at *6 (declining to exercise its supervisory powers to suppress wiretap evidence and finding defendant “has no Fourth Amendment right, and the novel substantive due process right he asks this Court to create cannot be described as a recognized right.” (internal citations omitted)).
6. The Defendant Is Not Entitled to a Hearing
The defendant argues that if the Court is “disinclined” to grant the extraordinary relief of suppression she seeks, she is entitled to an evidentiary hearing to probe the Government’s
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DOJ-OGR-00003072
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