United States v. Elkins
Citation and Court
364 U.S. 206 (1960) — Supreme Court of the United States
Facts
State officers illegally searched Elkins’s home and seized evidence. They then turned that evidence over to federal officers, who used it in a federal prosecution. Under the prior “silver platter doctrine,” evidence illegally seized by state officers was admissible in federal court if federal agents were not involved in the illegal search.
Issue
Whether evidence illegally seized by state officers in violation of the Fourth Amendment may be admitted in a federal criminal trial under the silver platter doctrine.
Holding
No; the silver platter doctrine is abolished. Evidence obtained by state officers in violation of the Fourth Amendment is inadmissible in federal court.
Rule / Doctrine
Prior to Elkins, federal courts could accept evidence on a “silver platter” from state officers who had violated the Constitution, as long as federal officers were not complicit. Elkins eliminated this doctrine, holding that the legality of a search must be judged by federal constitutional standards regardless of whether the searching officers were federal or state. The exclusionary rule applies to both.
Significance
Critical step toward the full incorporation of the exclusionary rule. Elkins ended the silver platter doctrine and set the stage for Mapp v. Ohio (1961), which applied the exclusionary rule to the states through the Fourteenth Amendment.