since he was the original defendant, Janis carried this burden of proof. In his appeal, he needed to prove to the Court that the tax assessment made on him was incorrect. If this could not be done, Janis needed to provide what the correct assessment should have been. The Supreme Court felt he failed to prove his case. Logic would then take the side of the government and declare the tax assessment just. However, the true predicament of the case is that the government failed to prove their case either. The assessment made by the IRS was found to be “naked” because of the issue of the faulty warrant. To determine which side was innocent and which was guilty, the Court first went through a lengthy history of the Fourth amendment. They established the fact that there is a solid argument for both sides; on one hand the lower courts ruled that the evidence had been illegally obtained, and thus the assessment this evidence yielded is not valid. On the other hand, the government makes a convincing case that the assessment was legal, even if the evidence was obtained with a faulty warrant. As the Court puts it, the officer that obtained the evidence and the agency that analyzed it (the IRS) are two separate “sovereigns”. The Court closely notes that Janis cited several instances where the exclusionary rule has been extended to civil cases, however all of these instances were “intrasovereign”, not “intersovereign”. Compton v. United States was cited, a case in which the Fourth Circuit Court determined that the fact that evidence is seized illegally by the police is irrelevant to a tax assessment made by the IRS. This case was strikingly similar to the one at hand and provided key case law for the decision. Opinions of the Court Majority Opinion The majority opinion was written by Justice Harry A. Blackmun. Chief Justice Warren E. Burger, along with Justices White, Powell, and Rehnquist joined in the majority opinion. The Supreme Court came to the conclusion that the use of this evidence seized unconstitutionally by a state officer does not “outweigh the societal costs imposed by the exclusion.” Therefore, they do not think it is fair to exclude the evidence from a federal institution, like the IRS. They believe this because it “falls outside the offending officer’s zone of primary interest.” In their concluding statement, the Court said