Lanza v. New York

Summary

The Court affirmed Lanza's conviction for refusing to answer a legislative committee's questions after receiving immunity. Justice Stewart's opinion concluded that at least two questions arose independently of the intercepted jail conversation and that the record did not support the claim that the interception caused Lanza to be summoned. Those grounds sustained the conviction without deciding whether unconstitutional eavesdropping could otherwise justify refusing to testify. The opinion's broader discussion of jail privacy, standing, and the exclusionary rule was unnecessary to the result and did not command five votes. Justice Harlan joined on the understanding that the opinion did not incorporate the Fourth Amendment into the Fourteenth or necessarily equate their privacy protections. Chief Justice Warren, joined by Justices Douglas and Brennan, agreed with Brennan's independent-state-ground analysis and criticized the unnecessary constitutional discussion. Justice Brennan, joined by Warren and Douglas, likewise objected to that discussion and maintained that an adequate independent state ground supported the judgment, suggesting that dismissal as improvidently granted might be the proper disposition.