Note 64 — AMENDMENT 4

Weeks v. United States, 232 U.S. 383 (1914). This case was a virtual repudiation of Adams v. New York, 192 U.S. 585, 597 (1904). There the Supreme Court had ruled that in criminal proceedings in a State court the use of private papers obtained by unlawful search and seizure "was no violation of the constitutional guaranty of privilege from unlawful search or seizure." It added: "Nor do we think the accused was compelled to incriminate himself."