United States v. Calandra - Significance

In United States v. Calandra, the Supreme Court made it clear that the exclusionary rule was not a personal constitutional right, but was simply meant as a remedy to safeguard Fourth Amendment rights through its deterrent effect.

In connection with an extensive investigation into suspected illegal gambling, the police obtained a search warrant for the Royal Machine & Tool Co. in Cleveland, Ohio. This business was owned by John Calandra. The warrant specified that the objects of the search were bookmaking records and wagering paraphernalia. The warrant was based on information from informants to the FBI and surveillance by the FBI. On 15 December 1970, federal agents spent four hours searching the premises. The agents did not find any gambling paraphernalia, but they did find a card indicating that Dr. Walter Loveland was making periodic payments to Calandra. The agents seized the card along with books, records, stock certificates, and address books.

On 1 March 1971, a special grand jury convened in the Northern District of Ohio to investigate possible loan sharking activities. The grand jury subpoenaed Calandra to question him. Their questions were based on the material seized in the search of his business. On 17 August 1971 Calandra appeared before the grand jury but refused to testify, invoking the Fifth Amendment, which states that people may not be compelled to be a witness against themselves. The government asked the district court to grant Calandra immunity. Calandra got a postponement of the immunity hearing so he could prepare a motion to suppress the evidence seized in the search.

Calandra asked that the evidence be suppressed and returned because the warrant was insufficient and the search went beyond the scope of the warrant. The district court ordered the evidence suppressed and returned and said that Calandra did not need to answer any grand jury questions based on the suppressed evidence. The court agreed that the search warrant had been issued without probable cause, and the search had exceeded the scope of the warrant. The Court of Appeals for the Sixth Circuit agreed with the district court. The case next went to the Supreme Court.