Weeks v. United States, 232 U.S. 383, 58 L. Ed. 652, 34 S. Ct. 341 (1914) extended the exclusionary rationale in federal cases. There, a defendant convicted of illegal gambling moved before trial for the return of private letters he claimed were seized in violation of the Fourth Amendment. The Court agreed that the seizure there violated the Constitution and that the property had to be returned to the defendant before trial. Accordingly, because the Fifth Amendment prohibited the issuance of a subpoena for production of the letters, the government could not produce them at trial.