Facts
- Federal agents executed a search warrant at John P. Calandra’s business seeking gambling-related “bookmaking records and wagering paraphernalia.”
- During the search, an agent seized a document believed to relate to a separate loansharking investigation, though it was outside the warrant’s described items.
- A federal grand jury investigating loansharking subpoenaed Calandra and questioned him using information derived from the seized document.
- Calandra refused to answer; the government obtained transactional immunity to compel his testimony.
- Calandra moved to suppress the seized evidence, arguing the warrant affidavit was insufficient and the agents exceeded the warrant’s scope.
- The district court suppressed the evidence and ordered Calandra need not answer grand jury questions based on it.
- The Sixth Circuit affirmed on the ground that the exclusionary rule barred use of unlawfully seized evidence in grand jury proceedings.
- The Supreme Court granted review.
Issues
- Whether a grand jury witness may refuse to answer questions because they are based on evidence obtained through an unlawful search and seizure.
- Whether the Fourth Amendment exclusionary rule requires suppression of illegally seized evidence in federal grand jury proceedings.
Decision
- The Supreme Court reversed.
- The Court held that a witness may not refuse to answer grand jury questions on the ground that they are derived from an unlawful search and seizure.
- The Court held the exclusionary rule does not apply to suppress evidence in grand jury proceedings.
Legal Principles
- The Fourth Amendment exclusionary rule is a judicially created remedy aimed primarily at deterring unlawful police conduct, not a personal constitutional right of an aggrieved party.
- The rule applies only where its deterrent effect justifies its institutional costs; it does not bar use of illegally obtained evidence in all settings.
- Extending suppression litigation to grand jury proceedings would substantially burden the grand jury’s investigative function and delay investigations, while adding only minimal additional deterrence beyond trial-level suppression.
- Grand jury questioning based on unlawfully seized evidence is a derivative use and does not itself constitute a new or independent Fourth Amendment violation.
- If an indictment follows, the defendant retains the ability to seek suppression of illegally obtained evidence at trial.
Conclusion
The Court ruled that the exclusionary rule does not restrict a federal grand jury from questioning a witness using information derived from an unlawful search, and a witness cannot refuse to answer on that basis, leaving suppression to be addressed in later trial proceedings if charges are brought.