The IRS conducted an investigation into the financial practices of certain American citizens at a Bahamian bank. When a representative of the bank came to the United States, an IRS agent stole his briefcase and photocopied its contents. As a result of the evidence obtained, Payner was charged with tax fraud. Although the district court ruled that Payner did not have standing to challenge the search and seizure of the bank representative’s papers, the district court invoked its supervisory powers to exclude the evidence. The United States Court of Appeals for the Sixth Circuit affirmed. The United States Supreme Court granted certiorari.