Irvine v. California (1940)
- Docket
- 12
- Decided
- 1940-1955-
Summary
Question: Should evidence obtained in violation of the Fourth Amendment prohibiting unreasonable searches and seizure require the exclusion of such evidence in a state court trial for violation of state criminal law? Conclusion: No. In a 5-4 decision, the Court upheld Irvine's conviction though without commanding a majority as to the Court's reasoning. Announcing the judgment and writing for a plurality, Justice Robert H. Jackson acknowledged and criticized the conduct of the police, which "flagrantly, deliberately, and persistently violated the fundamental principle declared by the Fourth Amendment." However, as in Wolf v. Colorado , "the Fourteenth Amendment does not forbid the admission of evidence obtained by an unreasonable search and seizure." The evidence obtained from the microphone did not have to be excluded from Irvine's trial, and was admitted consistent with the Fourteenth Amendment. Therefore, though Irvine's constitutional rights were violated, his conviction was nonetheless valid. Justice Tom C. Clark authored a concurring opinion.