Week 9 Case Briefs
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Jan 9, 2024
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Aisha Vasquez
Constitutional Law LAW203
United States V. Hartwell No. 04-3841
Decided: January 31
st
, 2006 FACTS:
Hartwell arrived at Philadelphia International Airport on May 17
th
, 2003, intending to catch a flight to Phoenix. He reached the security checkpoint, placed his hand luggage on a conveyor belt to be x-rayed, and approached the metal detector. Hartwell’s luggage was scanned without incident, but he set
off the magnetometer when he walked through. He was told to remove all items from his pockets and try again. Hartwell removed several items-including a large quantity of cash from his pocket and passed through again. TSA agent Carlos Padua took Hartwell aside after he passed through the metal detector a
second time, he used a handheld wand-like magnetometer to discover what set off the metal detector. The wand revealed a solid object in Hartwell’s cargo pants pocket. Padua asked what it was, but Hartwell
did not respond. Hartwell claims that he was escorted to a private screening room near the checkpoint, where he refused Padua’s repeated requests to reveal the contents of his pockets. Frustrated by Hartwell’s unresponsiveness, Padua eventually reached into Hartwell’s pocket and pulled out a package of drugs. He immediately called Philadelphia police, who searched Hartwell, found two additional packages of drugs and about $3,000 in cash and promptly arrested him. The government claims that neither Padua nor the police officer ever reached into Hartwell’s pocket without his consent. After requesting a private screening, Hartwell refused several requests to empty his pockets, nervously backed
away from Agent Padua while he was being questioned and suddenly dropped his pants. This suspicious behavior prompted Padua to call for backup. A police officer arrived and asked Hartwell to remove any items from his pockets, and Hartwell complied by handing over one package of drugs. He then feigned falling to the floor and dropped a second package of drugs. ISSUES:
The legal issue in this case is that Hartwell was searched at an airport security checkpoint where a magnetic wand found a solid object in his pocket that turned out to be crack cocaine. There is a dispute
about whether Hartwell consented to the search, but the court found that the search was justified based
on undisputed facts. This case is being heard in court because Hartwell argued that the drugs should have been suppressed because the search offending the Fourth Amendment. They decided that the search was permissible under the administrative search doctrine. The problem is whether airport security searches that are conducted without individualized suspicion are constitutional under the Fourth Amendment. LEGAL DECISION:
The court found it necessary to resolve those conflicting accounts, finding that the search was justified based on undisputed facts. The court concluded that Hartwell’s search does not offend the Fourth Amendment even though it was initiated without individualized suspicion and was conducted without a warrant. It is permissible under the administrative search doctrine because the state has an overwhelming interest in preserving air travel safety, and the procedure is tailored to advance that interest while proving to be only minimally invasive as that term is understood. The search
was reasonable under the Fourth Amendment, so the police did not violate the plaintiff's Fourth Amendment rights. LEGAL RATIONALE: The court first held that the search passed muster under the Fourth Amendment’s general proscription against unreasonable searches and seizures. The constitutional principle that the court based its decision on is the search doctrine which is when a private actor find evidence of criminal conduct after searching someone else's person, house, papers and effects without a warrant, the government use the evidence.
Aisha Vasquez
Constitutional Law LAW203
November 10
th
, 2023 United States V. Lee 455 U.S. 252 (1982) No. 80-767 Argued: November 2
nd
, 1981---------Decided: February 23
rd
, 1982
FACTS:
Edwin Lee, a member of the Old Order Amish, employed several other Amish workers on his farm
and in his carpentry shop. He did not pay quarterly social security taxes, and in 1978, the Internal
Revenue Service (IRS) assessed $27,000 in unpaid taxes. Lee paid the portion due for the first quarter of
1973 and sued for a refund. Lee argued that the tax violated his First Amendment right to free exercise
of religion. In the Amish religion, it is a sin not to provide for the community’s elderly and needy citizens.
Lee argued that paying the federal government for Social Security violates that provision of his religion
by giving the responsibility of caring for the elderly and needy to the government. The district court held
that the court noted 1402(g) provides an exception to the social security tax for certain self-employed
individuals. The U.S Supreme Court heard this case on direct appeal. ISSUES:
The legal issue in this case is that the federal government could collect social security taxes from
Edwin Lee, an Amish employer who objected to the taxes on religious grounds. This case is being heard
in court because the district court ruled that the laws requiring Lee to pay the taxes were
unconstitutional under the First Amendment. The court also said the laws conflicted with 26 U.S.C. which
exempted self-employed Amish from social security taxes on religious grounds. The problem in this case
is that he failed to withhold social security taxes from employee paychecks, and he did not pay the
employer’s share of those taxes. The police violated the plaintiff’s First Amendment because Lee alleged
payment of social security taxes violated his right to free religious exercise under the First Amendment
since the Amish have religious obligation for members of their community. LEGAL DECISION:
The court concluded that the federal government could collect social security taxes
from Edwin Lee, an Amish employer who objected to the taxes on religious grounds. Chief Justice
Warren Burger wrote the majority opinion reversing and remanding. The court held that the tax was not
unconstitutional as applied. By becoming an employer, Lee entered into commercial activity and
accepted certain limits on the exercise of his beliefs. The Supreme Court decided 9-0 that the
government had an essential interest in collecting employment taxes from Lee that justified the
limitation of his religious liberty under the First Amendment. The District Court concluded that the Free
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Exercise Clause prohibits forced payments of social security taxes when payment of taxes and receipt of
benefits violate the taxpayer’s religion. LEGAL RATIONALE:
The constitutional principle the court based its decision on is that the District Court
held the statutes requiring appellee to pay social security taxes unconstitutional as applied, basing its
holding on both 26 U.S.C which exempts from social security taxes, on religious grounds, self-employed
AMish and others, and the First Amendment. Lee argued that paying the federal government for Social
Security violates that provision of his religion by giving the responsibility of caring for the elderly and
needy to the government.
Aisha Vasquez
Constitutional Law
LAW203
Kyllo V. United States
Certiorari to the United States Courts of Appeals for the Ninth Circuit
No. 99-8508
Argued: February 20
th
, 2001-Decided: June 11
th
, 2001
FACTS:
A department of the Interior agent, suspicious that Danny Kyllo was growing Marijuana, used a thermal imaging device to scan his triplex. The imaging was to be used to determine if the amount of the
heat emanating from the home was consistent with the high-intensity lamps typically used for indoor marijuana growth. Subsequently, the imaging revealed Kyllo’s garage roof and a side wall were hot compared to the rest of his home and substantially warmer than the neighboring units. Based on informants, utility bills and thermal imaging, a federal magistrate judge issued a warrant to search Kyllo’s home where agents found marijuana growing. After Kyllo was indicted on a federal charge, he unsuccessfully moved to suppress the evidence seized from his home and then entered a conditional plea. The Ninth Circuit ultimately affirmed, upholding the thermal imaging on the ground that Kyllo had shown no subjective expectation of privacy because he had made no attempt to conceal the heat escaping from his home. Even if he had, ruled the court, there was no objectively reasonable expectation
of privacy because the thermal imager did not expose any intimate details of Kyllo’s life, only amorphous hot spots on his home exterior. ISSUES:
The legal issue is whether the use of thermal imaging to record the relative amount of heat emanating from the exterior of a house constitutes a “search” within the meaning of the Fourth Amendment. This case is being heard in court because the government used a device that is not in public
use, to explore details of a private home that would previously have been unknowable without physical intrusion, the surveillance is a Fourth Amendment “search” and is presumptively unreasonable without a
warrant. The problem in this case is that the use of thermal imaging devices to monitor heat radiation is unconstitutional. It was unable to reveal any information about specific activities or conversation that occurred in the home but there were no violations of Kyllo’s privacy or his Fourth Amendment. LEGAL DECISION:
The court ruled that the use of thermal imaging devices to monitor heat radiation in or
around a person’s home, even if conducted from a public vantage point, is unconstitutional without a
search warrant. The court held that observations were made with a primitive thermal imager that gathered data exposed on the outside of Kyllo’s home but did not invade any constitutionally protected interest in privacy. The court held that the police were using devices to explore details of the home would previously have been unknowable without physical intrusion. LEGAL RATIONALE:
The constitutional principle the court based its decision on is that the surveillance is a Fourth Amendment “search” and is presumptively unreasonable without a warrant. Based on this criterion, the information obtained by the thermal imager in this case was the product of a search. The court rejects the Government’s argument that the thermal imaging must be upheld because it detected only heat radiating from the home’s external surface. Reversing that approach would leave the homeowner at the mercy of advancing technology including imaging technology that could discern all human activity in the home.
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