William Parks, a special agent of the U.S. Customs Service, was investigating allegations that Bet-Air, Inc. (a seller of spare aviation parts and supplies) had supplied restricted military parts to Iran. Parks entered Bet-Air's property and removed a bag of shredded documents from a garbage dumpster. The dumpster was located near the Bet-Air offices in a parking area reserved for the firm's employees. To reach the dumpster, Parks had to travel 40 yards on a private paved road. No signs indicated that the road was private. In later judicial proceedings, Parks testified that at the time he traveled on the road, he did not know he was on Bet-Air's property. When reconstructed, some of the previously shredded documents contained information seemingly relevant to the investigation. Parks used the shredded documents and the information they revealed as the basis for obtaining a warrant to search the Bet-Air premises. In executing the search warrant, Parks and other law enforcement officers seized numerous documents and Bet-Air records.
A federal grand jury indicted Bet-Air's chairman, Terence Hall, and other defendants on various counts related to the alleged supplying of restricted military parts to Iran. Contending that the Fourth Amendment had been violated, Hall filed a motion asking the court to suppress (i.e., exclude) all evidence derived from the warrantless search of the dumpster and all evidence seized during the search of the Bet-Air premises (the search pursuant to the warrant). The federal district court denied Hall's motion. Following a jury trial, Hall was convicted on all counts and sentenced to prison. He appealed, again arguing that the Fourth Amendment was violated. How did the appellate court rule? Was there a Fourth Amendment violation?

  • CreatedJuly 16, 2014
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