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Who won Smith v Maryland?

Published in Constitutional Law 2 mins read

Maryland won the landmark Supreme Court case, Smith v. Maryland.

Understanding the Outcome

The Supreme Court of the United States delivered a ruling in 1979 in favor of the state of Maryland in the pivotal case of Smith v. Maryland. This decision had significant implications for privacy rights and law enforcement's investigative methods.

Key Aspects of the Ruling

The core of the Supreme Court's decision centered on whether the use of a pen register—a device that records numbers dialed from a telephone—violated an individual's Fourth Amendment rights. The Fourth Amendment protects individuals against unreasonable searches and seizures.

The Court's reasoning for ruling in Maryland's favor was based on a critical interpretation of privacy:

  • No Reasonable Expectation of Privacy: The Supreme Court concluded that individuals do not have a reasonable expectation of privacy concerning the telephone numbers they dial. When a person dials a number, they voluntarily convey that information to the telephone company to complete the call.
  • Third-Party Doctrine Reinforcement: This ruling solidified the "third-party doctrine," which generally holds that individuals forfeit their expectation of privacy in information they willingly share with third parties, such as a phone company. Since the phone company records dialed numbers in the ordinary course of business, obtaining these records was not considered a "search" requiring a warrant under the Fourth Amendment.

Why Maryland Prevailed

The Court determined that because the act of dialing a phone number inherently involves transmitting that information to the telephone company, Michael Lee Smith, the petitioner, could not reasonably expect that these numbers would remain private from government inspection without a warrant. Consequently, the installation and use of a pen register by law enforcement did not constitute a Fourth Amendment violation, leading to Maryland's victory in the case.