been extorted from her, it will be of no prejudice to her on the trial." Additionally, a defendant could sue to suppress and regain possession of at least some types of illegally seized evidence, in a common law action for replevin. However, in the 1783 case of Ceglinski v. Orr, the English courts declined to suppress evidence obtained by illegal coercion. In the Warickshall case, evidence was gathered as a result of an involuntary confession, and the court held that the evidence (but not the confession itself) could be admitted. It is questionable whether the Warickshall rule became known in the United States before 1789 (when the U.S. Bill of Rights was written), and whether it applied to confessions obtained by both governmental and private parties. In any event, no decision by the Supreme Court of the United States has ever endorsed the Warickshall rule as a constitutional matter. Generally speaking, English law before 1789 did not provide as strong an exclusionary rule as the one that later developed under the Fourth Amendment to the United States Constitution, regarding unlawful searches and seizures. The Fourth Amendment, after all, was partly a reaction against English law including the general warrant and the writs of assistance. In the 1886 case of Boyd v. United States, the U.S. Supreme Court addressed compulsory production of business papers, and the Court excluded those papers based on a combination of the Fourth and Fifth Amendments. Boyd was closely limited to its facts, and several years later the Court stated that the Fourth Amendment does not extend to "excluding testimony" about wrongful searches and seizures. In 1897, the U.S. Supreme Court held, in Bram v. United States, that involuntary confessions are inadmissible as evidence. The Court in Bram did not announce a strong version of the exclusionary rule that would apply uniformly to exclude all evidence gathered in violation of the Bill of Rights, but instead announced a weak version that excluded only self-incriminating testimony that was compelled in violation of the Fifth Amendment. The distinction between testimonial versus other self-incriminating evidence is a matter of continuing debate. Before a strong version of the exclusionary rule was addressed and adopted by the federal courts, it had already been adopted by at least one state court, namely the Iowa Supreme Court, as that court would later describe: In 1914, the U.S. Supreme Court announced a strong version of