United States v. Raddatz

In United States v. Raddatz, 447 U.S. 667 (1980), the Supreme Court held that the Federal Magistrates Act did not require a district court judge to rehear the live testimony and independently evaluate the credibility on which the magistrate based his findings and recommendations on a motion to suppress. Id. at 680-81. As the Court noted: "A defendant who has not prevailed at the suppression hearing remains free to present evidence and argue to-and may persuade-the jury that the confession was not reliable and therefore should be disregarded." Id. at 678. The interests at stake in a suppression hearing are "of a lesser magnitude" than those in the criminal trial itself. Id. at 679. Furthermore, "at a suppression hearing, the court may rely on hearsay and other evidence, even though that evidence would not be admissible at trial." Id. In Raddatz, the magistrate heard live testimony and was therefore able to determine credibility from seeing and hearing the witnesses. The magistrate then made factual findings and recommendations to the district court which was free to exercise its discretion to conduct another hearing and view the witnesses itself. Id. at 680-81. Thus, the defendant "was afforded procedures by which a neutral decisionmaker, after seeing and hearing the witnesses, rendered a decision." Id. at 684 (Blackmun, J., concurring). The Supreme held, based on a challenge to the Federal magistrates Act (28 USC smark 636[b][1]), that the purpose and design of that statute are akin to CPL smark 255.20(4). The federal statute authorized a District Court to refer a suppression motion to a Magistrate. The district judge may designate a magistrate to conduct hearings, and to submit "to a judge of the court" (Id at 673), proposed findings of fact and recommendations for the disposition, by a judge of the court.