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Keywords

plaintiffdefendantstatutedue processseizurerelevance
plaintiffdefendantappealtrialtestimonywillobjectionseizureadmissibility

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Adams v. People of State of New York, 192 U.S. 585, 24 S.Ct. 372, 48 L.Ed. 575

Facts

The plaintiff in error was convicted of possessing gambling paraphernalia used in the game of policy, which is a lottery scheme. During a police raid on his premises, approximately 3,500 policy slips were found, along with other private papers. The defendant objected to the admission of these private papers as evidence, claiming they were seized unlawfully and violated his constitutional rights.

‘About 3,500 of these slips were found in the office occupied by the plaintiff in error, which was searched by certain police officers holding a search warrant. The officers took not only the policy slips, but certain other papers, which were received in evidence against the plaintiff in error at the trial, against his objection, for the purpose of identifying certain handwriting of the defendant upon the slips, and also to show that the papers belonged to the defendant, and were in the same custody as the policy slips.’

Issue

Did the admission of the defendant's private papers, seized during a police raid, violate his constitutional rights against unreasonable searches and seizures, and did the statutes under which he was convicted deprive him of due process and equal protection under the law?

‘First. That the court erred in holding that by the reception in evidence of the defendant's private papers seized in the raid of his premises, against his protest and without his consent, which had no relation whatsoever to the game of policy, for the possession of papers used in connection with which said game he was convicted, his constitutional right to be secure in his person, papers, and effects against unreasonable searches and seizures was not violated, and that he was also thereby not compelled to be a witness against himself, in contravention of the 4th, 5th, and 14th Articles of Amendment to the Constitution of the United States.

Rule

The court ruled that evidence obtained through a search warrant, even if it included items not specified in the warrant, could be admissible if it was pertinent to the case. Additionally, the possession of gambling paraphernalia could be considered presumptive evidence of illegal activity.

‘It may be mentioned in this place that though papers and other subjects of evidence may have been illegally taken from the possession of the party against whom they are offered, or otherwise unlawfully obtained, this is no valid objection to their admissibility if they are pertinent to the issue. The court will not take notice how they were obtained, whether lawfully or unlawfully, nor will it form an issue to determine that question.’

Analysis

The court determined that the private papers were relevant to establishing the defendant's connection to the policy slips and did not violate his rights. The court emphasized that the legality of the search warrant was not the issue; rather, the focus was on the relevance of the evidence obtained. The court also noted that the statutes in question were constitutional and did not infringe upon the defendant's rights.

‘We think there was no violation of the constitutional guaranty of privilege from unlawful search or seizure in the admission of this testimony. Nor do we think the accused was compelled to incriminate himself. He did not take the witness stand in his own behalf, as was his privilege under the laws of the state of New York. He was not compelled to testify concerning the papers or make any admission about them.’

Conclusion

The court affirmed the judgment of conviction, concluding that there was no violation of constitutional rights and that the evidence was admissible.

‘We find nothing in the record before us to warrant a reversal of the conclusions reached in the New York Court of Appeals, and its judgment will be affirmed.’

Who won?

The State of New York prevailed in this case, as the court upheld the conviction and the constitutionality of the statutes involved.

‘We find nothing in the record before us to warrant a reversal of the conclusions reached in the New York Court of Appeals, and its judgment will be affirmed.’

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