VonderAhe v. Howland

Dentist Donn VonderAhe and his wife, Barbara VonderAhe (plaintiffs) filed joint tax returns for 1966 and 1967, which the Internal Revenue Service (IRS) audited. After reviewing records that Donn provided, an IRS agent recommended accepting the VonderAhes’ returns as filed. However, Donn’s former employees alerted the IRS that although Donn provided the IRS with records of his “regular” patients, Donn withheld records relating to “emergency” patients. Per the former employees, Donn kept the emergency-patient records on yellow sheets or green cards. Additionally, a dental-office employee told the IRS that she and Donn moved the yellow sheets and green cards to Donn’s home to make them unavailable to the IRS. Based on this information, the IRS obtained broad search warrants for Donn’s office and home. The warrants were not limited to yellow sheets or green cards but rather covered, among other things, all dental-patient records, appointment books, and financial records. The IRS executed the warrants, which resulted in extensive searches and the seizure of a wide swath of documents. The VonderAhes sued Roy Howland and others (collectively, the government) (defendants) pursuant to the federal courts’ inherent equitable powers, alleging that the warrants were overly broad and thus violated the Fourth Amendment to the United States Constitution. The VonderAhes sought the return of the seized property, an injunction against the IRS’s use of the seized property, the suppression of evidence in any criminal prosecution against them, and $15,000 for damage caused to Donn’s practice. The district court denied the VonderAhes’ motion for a preliminary injunction and granted the government’s motion to dismiss. The VonderAhes appealed, arguing that the searches and seizures violated the Fourth Amendment and that the VonderAhes’ damages claim was proper.