Parties: Charles Katz (Defendant-Applicant) v. United States (Plaintiff-Respondent)
Facts: Katz had long been suspected by police to be involved in the local illegal gambling scene. In an effort to obtain credible evidence of his illegal activities, the police placed Katz under surveillance (Katz v United States, 1967). That surveillance revealed that Katz liked to use a particular phone booth, which police suspected Katz used to place bets. Consequently, the police attached a “big” or listening device to the phone booth in order to record Katz’s conversation and hopefully obtain evidence against him. The bug was able to record Katz making bets and the police used those recordings to arrest and prosecute Katz.
Prior Proceedings: At trial, Katz sought the exclusion of the recordings for use against him because they method that the police used to obtain the recordings violated his Fourth Amendment rights. The trial court, however, denied, his request. As a result, based on those recordings, Katz was eventually convicted of illegal gambling. Katz appealed the conviction to the Ninth Circuit Court of Appeal, arguing again that the police violated the Fourth Amendment by attaching a bug to the phone booth the record his conversation. The Ninth Circuit, however, affirmed the trial court conviction. According to the court, settled Fourth Amendment jurisprudence held that the Fourth Amendment protected the privacy of specific protected areas, such as one’s home from physical invasion and since the police had not actually physically invaded the phone booth, the placement of the bug was legal in that it was only recording conversation (Scheider, 2009). Katz then appealed to the Supreme Court.
Issue Presented: Does the Fourth Amendment allow the state to place a listening device on a phone booth, to conduct the warrantless recording of a citizen’s conversations.
Argument of the Parties: Katz argued that the recordings were unreasonable. On the other hand, the state argued that since the officers had not actually physically entered the phone booth, under prior law, placing a bug on the booth was legal.
Holding: The placing of the big on the phone booth was a violation of Katz’s Fourth Amendment rights. The evidence of his illegal gambling recorded by the bug was illegally obtained and should have been excluded from his trial. The conviction should be overturned.
Rationale: The Fourth Amendment protects people and not places. Accordingly, it is not necessary for the state to physically intrude into a protected area before they violated the Constitution, although that would also be a violation of the Fourth Amendment. More relevantly, a violation of the Fourth Amendment occurs any time the state intrudes without a warrant into wherever a person has a reasonable expectation of privacy. In this case, Katz was not shouting to the world his betting calls but rather conducting them in a phone booth. Accordingly, he had a reasonable expectation that those conversations were private and therefore the police needed a warrant to record them/
Relation to Core Values of Integrity: This case relates to the core value of Integrity in that in conducting an investigation, while it might be easier for the police to bend or stretch the law in order to apprehend a suspect; that suspect is innocent until proven guilty and as such should be afforded the rights of all citizens including privacy. Moreover, even if it requires a little more work, obtaining a warrant in such a case as Katz, would have been the proper decision.
References
Katz v. United States, 389 U.S. 347 (1967). Retrieved on July 24, 2014, from http://www.law.cornell.edu/supremecourt/text/389/347
Scheider, H.A. (2009). Katz v. United States: The Untold Story. Retrieved on July 24, 2014, from http://www.mcgeorge.edu/Documnets/Publications/06_Schneider_Master1MLR40.pdy
