United States v. Calandra Case Brief Summary | Law Case Explained
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United States v. Calandra | 414 U.S. 338 (1974)
Grand juries are powerful investigative tools for prosecutors. They are permitted to consider a wide variety of evidence in deciding whether to indict a criminal defendant. But can grand juries consider evidence that was unconstitutionally searched or seized in violation of the Fourth Amendment? The United States Supreme Court addressed this issue in United States versus Calandra.
Federal agents searched John Calandra’s business for suspected illegal gambling activity. The agents found no evidence of gambling. But they did find evidence that led them to discover that Calandra had engaged in illegal loan-sharking, that is, engaging in extortionate credit transactions.
A federal grand jury investigated Calandra’s loan-sharking activities. The grand jury subpoenaed Calandra, seeking his testimony. Although a federal court gave Calandra immunity that prevented a violation of his Fifth Amendment right to silence, Calandra moved the court to suppress the loan-sharking evidence and also to prevent his immunized testimony under the Fourth Amendment. The court concluded that the agents had violated the Fourth Amendment when they searched and seized the evidence without probable cause and ruled that the grand jury couldn’t consider the evidence or force Calandra to testify about loan-sharking.
On appeal, the Sixth Circuit affirmed the district court’s order. The United States successfully petitioned the United States Supreme Court for cert.
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