United States v. Zein Hassan Isa

923 F.2d 1300, 1991 U.S. App. LEXIS 275, 1991 WL 1230
CourtCourt of Appeals for the Eighth Circuit
DecidedJanuary 10, 1991
Docket90-2137
StatusPublished
Cited by33 cases

This text of 923 F.2d 1300 (United States v. Zein Hassan Isa) 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
United States v. Zein Hassan Isa, 923 F.2d 1300, 1991 U.S. App. LEXIS 275, 1991 WL 1230 (8th Cir. 1991).

Opinion

JOHN R. GIBSON, Circuit Judge.

This is an appeal from an order of the district court 1 holding that electronic surveillance which recorded the commission of a murder was lawfully authorized and conducted under the Foreign Intelligence Surveillance Act, 50 U.S.C. §§ 1801-1811 (1988), and denying a motion to suppress the evidence obtained through that surveillance. Appellant contends that the district *1302 court erred by refusing to suppress tapes obtained from the electronic surveillance of his residence because (1) the surveillance lacked probable cause, and (2) the government conducted the surveillance unlawfully. He also argues that the district court’s ex parte, in camera review of the application for surveillance order, the surveillance order itself, and other materials relating to the surveillance violated his sixth amendment right to confrontation. We affirm the judgment of the district court.

The State of Missouri has charged Zein Hassan Isa and his wife, Maria Matías Isa, with first-degree murder of their sixteen-year-old daughter at their residence in St. Louis, Missouri. The State of Missouri intends to introduce at trial recordings of the actual murder and telephone conversations before and after the murder. The State of Missouri obtained the recordings from the Federal Bureau of Investigation, which had been conducting electronic surveillance of Zein Hassan Isa at his residence.

The FBI obtained a court order authorizing electronic surveillance of Isa pursuant to the Foreign Intelligence Surveillance Act. 50 U.S.C. §§ 1801-1811. To obtain such an order, a federal officer, after receiving the Attorney General’s approval, must submit an application to one of seven district judges, appointed by the Chief Justice to serve on the Foreign Intelligence Surveillance Court. 50 U.S.C. §§ 1803(a), 1804(a). The application must contain, inter alia, the identity of the target, a statement of reasons to believe that the target of the surveillance is a “foreign power or an agent of a foreign power,” specified information on the implementation of the surveillance, and a “certification” from a high ranking executive branch official stating that the official “deems the information sought to be foreign intelligence information” and that the “information cannot reasonably be obtained by normal investigative techniques.” 2 50 U.S.C. § 1804(a)(l)-(ll).

Before issuing an order authorizing electronic surveillance, the judge must make specific findings, including that “there is probable cause to believe that the target of *1303 the surveillance is a foreign power or an agent of a foreign power,” that the place “at which the electronic surveillance is directed is being used, or is about to be used, by a foreign power or an agent of a foreign power,” that the application properly proposes to minimize the intrusion upon the target’s privacy, and that the application contains the necessary statements and certifications. 50 U.S.C. § 1805(a). If the target is a “United States person,” 3 the judge must also find that all statements and certifications required by § 1804(a)(7)(E) are not clearly erroneous. 50 U.S.C. § 1805(a)(5). The judge considering the application may enter an ex parte order approving electronic surveillance. 50 U.S.C. § 1805(a). The order must contain specific information and required directions governing the surveillance. 50 U.S.C. § 1805(b).

Evidence obtained from a surveillance may be used in a criminal proceeding only in accordance with procedures outlined in 50 U.S.C. § 1806. First, the Attorney General must authorize use of the information in a criminal proceeding. 50 U.S.C. § 1806(b). Notification must then be provided to the court where the criminal proceeding is pending and to the “aggrieved person” 4 against whom the information will be offered. 50 U.S.C. § 1806(c), (d). The aggrieved person may file a motion to suppress on the ground that the surveillance was illegal. 50 U.S.C. § 1806(e). The government may seek its own determination of the legality of the surveillance by filing a petition in the United States District Court where the criminal trial is pending. 50 U.S.C. § 1806(f). If the Attorney General files an affidavit stating that disclosure or an adversary hearing would harm the national security of the United States, then the district court makes this determination ex parte based on an in camera examination of the relevant documents. Id. The court may disclose those materials to the aggrieved person “only where such disclosure is necessary to make an accurate determination of the legality of the surveillance.” Id. The district court’s order regarding the legality of the surveillance is final and “binding upon all courts of the United States and the several states except a United States court of appeals and the Supreme Court.” 50 U.S.C. § 1806(h).

After the Attorney General authorized the Circuit Attorney for the City of St. Louis to use information obtained in the surveillance of Isa in criminal proceedings against the Isas, the government brought this action in district court seeking a judicial determination of the legality of the surveillance. The Attorney General of the United States attached an Affidavit and Claim of Privilege to the government’s petition stating that “it would harm the national security of the United States to disclose or have an adversary hearing with respect to the documents of the United States Foreign Intelligence Surveillance Court.”

The district court conducted an in camera, ex parte review of the application for the surveillance order, the surveillance order itself, and related documents. United States v. Isa, No. 90-73CR (1) slip op. (E.D.Mo. June 18, 1990) (under seal).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Muhtorov
20 F.4th 558 (Tenth Circuit, 2021)
United States v. Major NIDAL M. HASAN
Army Court of Criminal Appeals, 2020
United States v. Mohammad
339 F. Supp. 3d 724 (N.D. Ohio, 2018)
United States v. Sami Osmakac
868 F.3d 937 (Eleventh Circuit, 2017)
United States v. Aziz
228 F. Supp. 3d 363 (M.D. Pennsylvania, 2017)
United States v. Amina Ali
799 F.3d 1008 (Eighth Circuit, 2015)
United States v. Mahamud Said Omar
786 F.3d 1104 (Eighth Circuit, 2015)
United States v. Huang
15 F. Supp. 3d 1131 (D. New Mexico, 2014)
United States v. Mahamud
838 F. Supp. 2d 881 (D. Minnesota, 2012)
United States v. Shukri Baker
664 F.3d 467 (Fifth Circuit, 2011)
United States v. El-Alamin
574 F.3d 915 (Eighth Circuit, 2009)
United States v. Abu-Jihaad
531 F. Supp. 2d 299 (D. Connecticut, 2008)
United States v. Mubayyid
521 F. Supp. 2d 125 (D. Massachusetts, 2007)
Global Relief Foundation, Inc. v. O'NEILL
207 F. Supp. 2d 779 (N.D. Illinois, 2002)
United States v. Squillacote
221 F.3d 542 (Fourth Circuit, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
923 F.2d 1300, 1991 U.S. App. LEXIS 275, 1991 WL 1230, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-zein-hassan-isa-ca8-1991.