United States v. Payner

During an IRS investigation into Americans' financial dealings at a Bahamian bank, an IRS agent stole a bank representative's briefcase and photocopied its contents; Payner (defendant) was charged with tax fraud based on evidence obtained from that theft. The district court found Payner lacked Fourth Amendment standing to challenge the search of the bank representative's papers since he was not the victim of the theft, but nonetheless invoked its supervisory powers to exclude the evidence anyway; the Sixth Circuit affirmed, and the government sought Supreme Court review.