Criminal Law

United States v. Snap — Study Notes

987 F.3d 256 (9th Cir. 2023)

Study notes for United States v. Snap: professor notes, cold call prep, exam angles, and memory aids.

Warrantless searches require exigent circumstances or valid exceptions; otherwise, evidence is inadmissible.
Professor Notes

In United States v. Snap, the Ninth Circuit underscores the importance of the Fourth Amendment's protection against unreasonable searches and seizures, emphasizing that law enforcement must adhere to constitutional requirements even when faced with pressing circumstances. The case serves as a critical reminder that anonymous tips, without corroborating evidence or exigent circumstances, do not justify warrantless searches. Professors might stress that this decision reinforces the exclusionary rule, which aims to deter police misconduct by rendering unlawfully obtained evidence inadmissible in court.

Moreover, this case highlights a significant trend in Fourth Amendment jurisprudence, wherein courts are increasingly cautious about the sources of information that allow for searches. By ruling the evidence inadmissible, the court not only protected individual rights but also communicated a strong message about maintaining the integrity of constitutional protections against arbitrary police actions.

Cold Call Prep
  1. 1What were the key facts that led to the Court's decision in United States v. Snap?
  2. 2Explain the significance of the exclusionary rule in this case.
  3. 3How did the court address the issue of anonymous tips in the context of the Fourth Amendment?
  4. 4What are the implications of the court's ruling for law enforcement practices?
  5. 5Discuss potential exceptions for warrantless searches that were not applicable in this case.
  6. 6How does the Snap case compare to other notable Fourth Amendment cases?
  7. 7What would the outcome have been if exigent circumstances were present?
Mnemonic Device

Snap - 'Search Not Allowed, Proof Excluded'

Distinguish From
CaseDistinction
Terry v. OhioTerry allows for brief investigative stops based on reasonable suspicion, contrasting with Snap where no reasonable basis existed for search.
Illinois v. GatesGates upheld a search based on a corroborated informant tip; Snap relied solely on an anonymous tip without corroboration.
Mincey v. ArizonaMincey found exigent circumstances justified a warrantless search; Snap lacked any such justification.
Policy Arguments

For the Rule

The exclusionary rule promotes accountability in law enforcement, ensuring that constitutional rights are protected and that law enforcement does not overreach.

Against the Rule

Critics argue that the exclusionary rule can impede justice by preventing the admission of relevant evidence, potentially allowing guilty parties to escape conviction.

Class Discussion Points
  • What constitutes an anonymous tip versus a reliable informant?
  • How do courts balance individual rights against the needs of law enforcement?
  • What are the broader implications of the exclusionary rule on the criminal justice system?
Exam Angle

This case is likely to appear on exams in discussions surrounding the Fourth Amendment, warrantless searches, and the applicability of the exclusionary rule. Students may be asked to analyze the court's reasoning and articulate the boundaries of permissible searches.

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