United States v. Payner
Citation and Court
447 U.S. 727 (1980), Supreme Court of the United States
Facts
IRS agents deliberately allowed an informant to steal and photograph a banker’s briefcase containing documents linking Payner to a tax fraud scheme. The agents knew the bank officer whose briefcase was taken had Fourth Amendment rights, but calculated that Payner, the target, lacked standing to challenge the search. Payner was convicted using the documents; the district court suppressed the evidence under its supervisory powers, but the Sixth Circuit affirmed.
Issue
Whether a federal court may exercise its supervisory powers to suppress evidence obtained through a Fourth Amendment violation directed at a third party, when the defendant lacks standing to bring a Fourth Amendment challenge himself.
Holding
Federal courts may not exercise their supervisory powers to suppress evidence in a criminal case when the defendant lacks Fourth Amendment standing to challenge the search, even if the government deliberately violated the rights of a third party to obtain that evidence.
Rule / Doctrine
Fourth Amendment standing is personal; a defendant may only challenge a search or seizure that violates his own reasonable expectation of privacy, not that of a third party. Courts may not use their inherent supervisory powers to circumvent the standing requirement and suppress evidence the defendant otherwise has no constitutional right to exclude.
Significance
Payner underscores the limits of the exclusionary rule and judicial supervisory powers. It demonstrates that the government may deliberately target a third party’s rights — if it calculates that the defendant lacks standing — without triggering suppression, a result widely criticized as encouraging deliberate constitutional violations. The case is regularly taught alongside Rakas v. Illinois and the personal nature of Fourth Amendment rights.