Intro

Citation: 256 U.S. 465 (1921).

Summary: A private individual ransacked McDowell’s office and stole his papers.  This was done without the participation or knowledge of any law enforcement officers.

The stolen papers were later handed over to the federal investigators who sought to use said papers in a grand jury investigation against McDowell for mail fraud.

McDowell sued the U.S. attorney for return of the stolen papers and also to prevent the use of said papers in the criminal investigation.

The U.S. Supreme Court permitted the use of the evidence by holding that, while the Fourth Amendment prohibited unreasonable searches and seizures through state action, it did not apply to the acts of private citizens.

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