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Case 1:20-cr-00330-PAE Document307 Filed 06/25/21 Page12 of 21
Williams, 467 U.S. 431, 446 (1984); United States v. Leon, 468 U.S. 897, 922 (1984). The Court
agrees that, at the very least, the exception to the exclusionary rule for inevitable discovery
applies to the documents that have since been unsealed and made public in the civil case. But
because the Court finds no violation of the Fourth Amendment, it concludes that none of the
documents should be suppressed.
C. Maxwell is not entitled to suppression under due process or the Court’s inherent
authority
Maxwell next argues that the materials must be suppressed because the Government
violated her due process rights in obtaining them. The gravamen of this claim is that the
Government misrepresented its prior contacts with BSF to Judge McMahon. Maxwell contends
that this misrepresentation violated her due process rights, or alternatively that the Court should
exercise its inherent authority to suppress the evidence obtained through the subpoena as a
sanction for governmental misconduct. She contends that even an inadvertent misstatement to a
court requires suppression of evidence obtained as a result. She further seeks an evidentiary
hearing to explore whether any misrepresentation by the Government in that hearing was
intentional.
The Supreme Court has recognized that federal courts have a limited inherent authority to
suppress evidence obtained in “willful disobedience of law.” United States v. Payner, 447 USS.
727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has
also cautioned that courts must exercise this power with restraint. /d. Thus, “the court should
not exercise its inherent or supervisory power ‘as a substitute for Fourth Amendment
jurisprudence.’” United States v. Lambus, 897 F.3d 368, 401 (2d Cir. 2018) (quoting United
States v. Ming He, 94 F.3d 782, 792 (2d Cir. 1996)). In situations where the Fourth Amendment
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Document Details
| Filename | DOJ-OGR-00004796.jpg |
| File Size | 686.8 KB |
| OCR Confidence | 94.4% |
| Has Readable Text | Yes |
| Text Length | 1,975 characters |
| Indexed | 2026-02-03 16:53:01.896632 |