Warden v. Hayden

387 U.S. 294 (1967)

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Nature of the Case

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Facts

The police were informed that an armed robbery had occurred and that Hayden (D) had thereafter entered a certain house. Minutes later they arrived there and were told by D's wife that she had no objection to their searching the house. D was arrested in an upstairs bedroom when it became clear he was the only man in the house. Weapons were found in a flush tank and in a washing machine clothing of the type the suspect was said to have worn was found. Ammunition was also found. These items were admitted into evidence without objection at D's trial. D was convicted of the armed robbery based, in part, on the introduction of a cap, a jacket, and trousers, which had been discovered during a search of D’s home. The clothing matched the description of clothing having been worn by the perpetrator of the armed robbery. The argument that D used, and the argument that eventually got D the habeas relief was that the state of Fourth Amendment law at the time did not allow seized items which were only 'mere evidence' of a crime to be admitted. The District Court denied the relief. A divided panel of the Court of Appeals for the Fourth Circuit reversed. The Court of Appeals believed that Harris v. United States, 331 U.S. 145, 154, sustained the validity of the search, but held that D was correct in his contention that the clothing seized was improperly admitted in evidence because the items had 'evidential value only' and therefore were not lawfully subject to seizure. The Supreme Court granted certiorari.