Walder v. United States
Citation and Court
347 U.S. 62 (1954) — Supreme Court of the United States
Facts
In a prior, unrelated case against Walder, heroin had been suppressed as illegally seized. In a later narcotics trial, Walder took the stand and voluntarily testified that he had never possessed narcotics. The government then used the previously suppressed heroin to impeach his sweeping denial.
Issue
Whether illegally seized evidence that has been suppressed may be used to impeach a defendant who voluntarily makes a false and sweeping denial on direct examination at trial.
Holding
Yes; the government may use suppressed evidence to impeach a defendant who takes the stand and makes broad voluntary statements inconsistent with that evidence.
Rule / Doctrine
The exclusionary rule bars the government from using illegally seized evidence in its case-in-chief to prove guilt. However, a defendant who takes the stand and affirmatively makes false statements that go beyond denying the specific charges — making sweeping denials — cannot use the exclusionary rule as a shield against impeachment. The purpose of the rule is not to license perjury.
Significance
Established the foundational impeachment exception to the exclusionary rule. Extended in Harris v. New York (un-Mirandized statements), U.S. v. Havens (cross-examination responsive to direct), and Kansas v. Ventris (Sixth Amendment violations).