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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 137 of 239
designed to deter illegal conduct.’” Coke, 2011 WL 3738969, at *6 (quoting United States v.
Hastings, 461 U.S. 499, 505 (1983)). “However, while there are times when a district court may
properly find it absolutely necessary[, in order] to preserve the integrity of the criminal justice
system, to suppress evidence under its inherent or supervisory authority, ‘the Supreme Court has
explained that a court’s inherent power to refuse to receive material evidence is a power that must
be sparingly exercised [only in cases of] manifestly improper conduct by federal officials.” United
States v. Lambus, 897 F.3d 368, 401 (2d Cir. 2018) (alterations and emphasis in original) (internal
quotations and citations omitted). The Second Circuit has “‘recognized that courts cannot fashion
their own sub-constitutional limitations on the conduct of law enforcement agents.’” /d. (quoting
United States v. Ming He, 94 F.3d 782, 792 (2d Cir. 1996)); see also United States v. Myers, 692
F.2d 823, 847 (2d Cir. 1982). “Accordingly, the court should not exercise its inherent or
supervisory power ‘as a substitute for Fourth Amendment jurisprudence, which adequately
safeguards against unlawful searches and seizures.’” Lambus, 897 F.3d at 401 (quoting Ming He,
94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) (“the supervisory
power does not extend so far” as to “confer on the judiciary discretionary power to disregard the
considered limitations of the law it is charged with enforcing”).
b. Discussion
By asking the Court to exercise its inherent authority, the defendant apparently means to
suggest that the Court should grant the relief she seeks, even if she has failed to establish a violation
of the Constitution or other governing law. The defendant fails to provide justification for the
extraordinary remedy of suppression or to cite persuasive case law in favor of such an
extraordinary use of the Court’s inherent authority.
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Document Details
| Filename | DOJ-OGR-00003071.jpg |
| File Size | 701.3 KB |
| OCR Confidence | 94.3% |
| Has Readable Text | Yes |
| Text Length | 2,049 characters |
| Indexed | 2026-02-03 16:30:24.358153 |