Criminal Procedure keyed to Weinreb
Wong Sun v. United States
Facts
Hom Way (“Way”) was found with heroin in his possession after being under surveillance by federal narcotics officer for six weeks. Way told the officer that he bought heroin from someone named “Blackie Toy.” After obtaining this information, six or seven federal agents went to the location where Way said he purchased the heroin. It was a Laundromat operated by James Wah Toy (“Toy”). There is nothing in the record that says Toy and “Blackie Toy” are the same person. One agent went to the front door and announced that he was a federal narcotics agent. When that occurred, Toy slammed the door and began running toward his living quarters in the back of the Laundromat. The agent who approached the door and other agents followed Toy into the bedroom. Toy reached into a nightstand drawer and was arrested. There was nothing in the drawer and there were no narcotics found on the premises. The officers informed Toy that Way said he purchased narcotics from him. Toy said that he never sold drugs, but knew someone named Johnny who did. Toy described the house Johnny lived in to the officers. The agents went the house Toy described and found Johnny Yee (“Yee”) in the bedroom. After speaking to the agents, Yee gave them several tubes containing heroin. Within an hour, Yee and Toy were taken to the Office of the Bureau of narcotics. While at the office, Yee said that Toy and another individual, “Sea Dog” brought the heroin to him a few days before. “Sea Dog” was Wong Sun. The agents took Toy to Wong Sun’s avenue and Toy showed them where Wong Sun lived. The agents arrested Wong Sun in his apartment. A search of the apartment did not turn up any narcotics. Toy and Yee were arraigned and released. Wong Sun was arraigned the next day and also released. A few days later, all three individuals were interrogated by another Narcotics agent. The agent advised the individuals of their right to withhold information and right an attorney. The three individuals were interrogated individually. A statement was then prepared for each individual. Toy refused to sign his statement and wanted to know if the others had signed. Wong Sun also did not sign the statement, but admitted the accuracy of the statement. “The Government’s evidence tending to prove the petitioners’ possession (the petitioners offered no exculpatory testimony) consisted of four items which the trial court admitted over timely objections that they were inadmissible as ‘fruits’ of unlawful arrests or of attendant searches: (1) the statements made orally by petitioner Toy in his bedroom at the time of his arrest; (2) the heroin surrendered to the agents by [ ] Yee; (3) petitioner Toy’s pretrial unsigned statement; and (4) petitioner Wong Sun’s similar statement.” The Court of Appeals held that the arrests were illegal because they were not based on “probable cause” within the meaning of the Fourth Amendment or “reasonable grounds” within the meaning of the Narcotic Control Act of 1956. “The Court of Appeals nevertheless held that the four items of proof were not the ‘fruits’ of the illegal arrests and that they were therefore properly admitted in evidence.”
Only StudyBuddy Pro offers the complete Case Brief Anatomy*
Access the most important case brief elements for optimal case understanding.
*Case Brief Anatomy includes: Brief Prologue, Complete Case Brief, Brief Epilogue
- The Brief Prologue provides necessary case brief introductory information and includes:
Topic:
Identifies the topic of law and where this case fits within your course outline.Parties:
Identifies the cast of characters involved in the case.Procedural Posture & History:
Shares the case history with how lower courts have ruled on the matter.Case Key Terms, Acts, Doctrines, etc.:
A case specific Legal Term Dictionary.Case Doctrines, Acts, Statutes, Amendments and Treatises:
Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
Brief Facts:
A Synopsis of the Facts of the case.Rule of Law:
Identifies the Legal Principle the Court used in deciding the case.Facts:
What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case.Issue(s):
Lists the Questions of Law that are raised by the Facts of the case.Holding:
Shares the Court's answer to the legal questions raised in the issue.Concurring / Dissenting Opinions:
Includes valuable concurring or dissenting opinions and their key points.Reasoning and Analysis:
Identifies the chain of argument(s) which led the judges to rule as they did.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
Policy:
Identifies the Policy if any that has been established by the case.Court Direction:
Shares where the Court went from here for this case.