Application and Affidavit for Search Warrant. Washington Post Company v. Hughes

923 F.2d 324, 18 Media L. Rep. (BNA) 1593, 1991 U.S. App. LEXIS 13
CourtCourt of Appeals for the Fourth Circuit
DecidedJanuary 2, 1991
Docket90-5550
StatusPublished
Cited by46 cases

This text of 923 F.2d 324 (Application and Affidavit for Search Warrant. Washington Post Company v. Hughes) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Application and Affidavit for Search Warrant. Washington Post Company v. Hughes, 923 F.2d 324, 18 Media L. Rep. (BNA) 1593, 1991 U.S. App. LEXIS 13 (4th Cir. 1991).

Opinion

923 F.2d 324

18 Media L. Rep. 1593

In the Matter of the APPLICATION AND AFFIDAVIT FOR A SEARCH WARRANT.
The WASHINGTON POST COMPANY, Plaintiff-Appellee,
v.
Caleb HUGHES, Defendant-Appellant,
United States of America; Commonwealth of Virginia, Amici Curiae.

No. 90-5550.

United States Court of Appeals,
Fourth Circuit.

Argued Dec. 4, 1990.
Decided Jan. 2, 1991.

Peter D. Greenspun, Klein & Greenspun, Fairfax, Va., for defendant-appellant.

Stephen Andrew Best, argued (Robert F. Horan, Commonwealth Attorney's Office, Fairfax, Va., on brief), for amicus curiae Com. of Virginia.

William G. Otis, Asst. U.S. Atty., argued (Henry E. Hudson, U.S. Atty., Alexandria, Va., on brief), for amicus curiae U.S.

Kevin Taylor Baine, argued (Dane H. Butswinkas, Williams & Connolly, Washington, D.C., on brief), for plaintiff-appellee.

Before ERVIN, Chief Judge, and WIDENER and WILKINSON, Circuit Judges.

WILKINSON, Circuit Judge:

This case involves the recurrent tension between the public's right of access to information regarding the workings of the criminal justice system and a defendant's Sixth Amendment guarantee of a fair trial. The specific conflict concerns an affidavit filed in support of a search warrant and whether the contents of that affidavit can be released without extinguishing the rights of the defendant at whom the warrant was directed. That defendant, Caleb Hughes, has been indicted on the charge of abduction with intent to defile. Hughes maintains that the information contained in the affidavit is so prejudicial that he will not be able to obtain a fair trial if it is unsealed. The federal district court in which the affidavit was filed ordered that it be unsealed in its entirety on the basis that properly conducted voir dire would ensure an unbiased jury verdict. Finding no abuse of discretion, we now affirm the district court's order.

I.

In December 1989, a five year old girl vanished from a community Christmas party she was attending with her mother in Fairfax County, Virginia. The Federal Bureau of Investigation became involved in the case and two weeks after the disappearance obtained a search warrant in the United States District Court for the Eastern District of Virginia for defendant Caleb Hughes' car. The request for the warrant was based on an FBI agent's sworn affidavit that summarized the gathered evidence. At that time the affidavit was sealed in order to protect the ongoing investigation and a federal magistrate denied a motion by the Washington Post to unseal the affidavit.

The young girl's disappearance sparked extensive media coverage in northern Virginia. Videotapes from the Christmas party were repeatedly shown on television and posters bearing the girl's photograph were disseminated throughout that area. Despite the publicity surrounding the disappearance and subsequent police investigation, the girl has never been found.

On November 19, 1990, almost a year after the girl vanished, a grand jury in Fairfax County indicted Hughes on the charge of abduction with the intent to defile, punishable by twenty years to life imprisonment. Following the indictment, the Post renewed its request that the federal court unseal the search warrant affidavit. Hughes opposed the motion on the grounds that release of any of the information in the document would prejudice him and compromise his Sixth Amendment right to a fair trial. Because the investigation had concluded, the United States agreed with the Post that most of the material in the affidavit could safely be released, but maintained that one paragraph should remain sealed because of its prejudicial potential. A federal magistrate held a hearing on the matter and denied the Post 's motion to unseal.1

The parties then immediately took their dispute to the federal district court. After hearing argument, that court ruled that the affidavit should be released in its entirety and that voir dire would ensure that Hughes would be tried before an impartial jury. The court nevertheless temporarily stayed its own order with regard to the one controversial paragraph in order to allow time for further appeal. A circuit judge extended the stay until a panel of this court could hear argument.

II.

We begin by detailing the deference that is owed in this area to the determinations of federal district courts. This circuit has held that a newspaper has a common law right of access to affidavits supporting search warrants, although not a First Amendment right of access. Baltimore Sun Co. v. Goetz, 886 F.2d 60 (4th Cir.1989). This "common law qualified right of access to the warrant papers is committed to the sound discretion of the judicial officer who issued the warrant." Id. at 65; see Nixon v. Warner Communications, Inc., 435 U.S. 589, 599, 98 S.Ct. 1306, 1312, 55 L.Ed.2d 570 (1978). We therefore review the district court's decision whether to grant access to or to seal the document under an abuse of discretion standard.2 Goetz, 886 F.2d at 65.

In this case, the district court balanced the public's right of access with the defendant's assertions that release would compromise his Sixth Amendment right to a fair trial. The mere fact that Hughes is asserting a constitutional right does not change the standard by which we review the district court's judgment. The decision in question is similar to any number of judgments a trial court makes that potentially affect a defendant's constitutional rights. For example, it is well established that we review charges that a trial court's curtailment of cross-examination denied defendant a fair trial under an abuse of discretion standard. See United States v. Crockett, 813 F.2d 1310, 1312-13 (4th Cir.1987); United States v. Bodden, 736 F.2d 142, 145 (4th Cir.1984).

The rationale for investing this particular balancing process at the trial court level is obvious. Each specific situation is different and discretion is best exercised "in light of the relevant facts and circumstances of the particular case." Warner Communications, 435 U.S. at 599, 98 S.Ct. at 1312-13. A trial court is in the best position to understand the intricate workings of criminal trial procedures, the varying methods of voir dire, jurors' responses to pretrial publicity, and whether a defendant can be granted a fair trial. Such fundamental aspects of trying a case are grist for the trial court's mill. Although appellate courts as well may have insights on these issues, deference is owed the practical experience and accumulated wisdom of a district court in this area. Trial judges are also best situated to understand the subtle factors unique to a given geographic area or population that may either attenuate or enhance the effect of any particular disclosure upon a defendant's rights.

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923 F.2d 324, 18 Media L. Rep. (BNA) 1593, 1991 U.S. App. LEXIS 13, Counsel Stack Legal Research, https://law.counselstack.com/opinion/application-and-affidavit-for-search-warrant-washington-post-company-v-ca4-1991.