Kiesel Co. v. Householder

879 F.2d 385, 1989 WL 75913
CourtCourt of Appeals for the Eighth Circuit
DecidedJuly 13, 1989
DocketNo. 88-1573
StatusPublished
Cited by1 cases

This text of 879 F.2d 385 (Kiesel Co. v. Householder) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kiesel Co. v. Householder, 879 F.2d 385, 1989 WL 75913 (8th Cir. 1989).

Opinions

JOHN R. GIBSON, Circuit Judge.

The United States appeals from a district court order requiring the return of property seized during execution of a search warrant against the Kiesel Company. The warrant, issued by another district judge, was ruled constitutionally overbroad because it described virtually all property on the Kiesel premises, both business and personal. Although Kiesel had sought relief under Federal Rule of Criminal Procedure 41(e), the district court instead asserted “anomalous” jurisdiction and proceeded in equity. As a result the district court did not permanently suppress the evidence, but instead required only that the government return the evidence to Kiesel and not use it at trial unless a proper warrant had been used to again seize the property. We reverse the order of the district court.

I.

The United States, following an extensive investigation by Federal Bureau of Investigation agent Kimberly Householder into possible violations by Kiesel of federal environmental law,1 applied to a federal district judge for a warrant to search the Kiesel business premises at 4801 Fyler Avenue, St. Louis. Agent Householder presented a lengthy affidavit to support the application, and the warrant was issued. It is not disputed that the scope of the warrant was extremely broad.2

[387]*387The search warrant was executed on February 29, 1988 by agents of the FBI and the Environmental Protection Agency, and the search took several days to complete. Eighty to one hundred boxes of records were seized. Kiesel responded by filing a motion for the return of the property under Federal Rule of Criminal Procedure 41(e). The district court ordered a prompt hearing, and the issues were thoroughly briefed.

The district court declined to order the government to return the property under Rule 41(e), looking to Rickert v. Sweeney, 813 F.2d 907 (8th Cir.1987) to support its view, as Rule 41(e) would require suppression of the property even where there had not been an indictment or other proceeding instituted. It chose to consider the matter as one in equity subject to the court’s anomalous jurisdiction, “following the apparent route of Bickert.” It did not, however, determine if traditional equitable requirements were met, but simply proceeded to the merits. Evaluating the warrant, the district court conceded that the suspected criminal activity was of such a complexity that some latitude was allowable in the descriptions of the property to be seized.3 Finding the warrant to authorize an all encompassing search, the court declared it unconstitutionally overbroad. It ordered the FBI to return to Kiesel all property taken under the authority of the warrant and enjoined the use of that property and information derived from it in any criminal investigations, but specified that the order was without prejudice. The government could thus once again seize and use any of Kiesel’s property if it obtained a narrower warrant.

The government appeals. It argues that the warrant was not overbroad because probable cause to suspect a substantial pattern of illegality has been established, and the principles of United States v. Kail, 804 F.2d 441 (8th Cir.1986), therefore apply. It points out that due deference should be accorded the ruling of the first district judge who issued the warrant. It also claims that the district court was wrong to exercise equitable jurisdiction without considering the factors set forth in Pieper v. United States, 604 F.2d 1131 (8th Cir.1979). Finally it argues that the officers executing the warrant acted in good faith, and that United States v. Leon, 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984), therefore requires dismissal. We have ordered the FBI’s affidavit to be unsealed, and both parties have been given the opportunity to submit additional comments based upon its contents.

II.

We begin by discussing the district court’s procedural approach to this case. It properly considered Kiesel’s claim as an equitable proceeding rather than a Rule 41(a) motion. “[A] motion prior to any suggestion of criminal proceedings, as here, is more properly considered as a suit in equity rather than one under the Rules of Criminal Procedure.” Richey v. Smith, 515 F.2d 1239, 1245 (5th Cir.1975). Having decided this, however, the district court failed to evaluate whether the circumstances of the case warranted the exercise of equitable jurisdiction. Our decision in Pieper, 604 F.2d at 1133, holds that such jurisdiction is proper only upon a showing of callous disregard of the fourth amendment, irreparable injury if relief is not granted, and lack of an adequate remedy at law. See also Richey, 515 F.2d at 1243-44; Hunsucker v. Phinney, 497 F.2d 29, 34-35 (5th Cir.1974), cert. denied, 420 U.S. 927, 95 S.Ct. 1124, 43 L.Ed.2d 397 (1975). Pieper, as well as its supporting authority, found such a showing necessary to establish “anamolous jurisdiction” so as to give it authority to proceed. In contrast, after [388]*388indictment exercise of the court’s jurisdiction is specifically authorized by Rule 41(e) of the Federal Rules of Criminal Procedure.

The district court, however, made no such analysis and considered none of these factors, instead asserting that the only issue to be decided was the specificity of the search warrant itself. It relied on Rickert v. Sweeney, 813 F.2d 907 (8th Cir.1987), and In re Grand Jury Proceedings, 716 F.2d 493 (8th Cir.1983), evidently believing that these cases obviated the need to consider the three Pieper factors. We do not read Rickert and Grand Jury Proceedings so broadly. Neither contains an explicit discussion of application of the three Pieper factors, but the opinions do not reveal that this issue was raised by the parties or considered by either the district court or this court in those cases. Our recent decision of In re Harper, 835 F.2d 1273, 1275 (8th Cir.1988), makes clear that the Pieper factors must still be met before equitable jurisdiction may be exercised.

III.

Thus, we must determine whether the district court abused its discretion by reaching the merits of Kiesel’s claim. See Harper, 835 F.2d at 1275. This is made difficult, of course, by the district court’s failure to analyze the equitable considerations underlying the facts of the case.

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Search of 4801 Fyler Avenue v. Householder
879 F.2d 385 (Eighth Circuit, 1989)

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Bluebook (online)
879 F.2d 385, 1989 WL 75913, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kiesel-co-v-householder-ca8-1989.