Whether the Federal Wiretap Act's exclusionary rule in 18 U.S.C. § 2515 applies to unlawfully intercepted communications regardless of whether the government had "clean hands" (i.e., did not participate in or encourage the unlawful interception), or whether the government's lack of participation in the interception constitutes an exception to the exclusionary rule.

Whether a federal court may judicially create a 'clean-hands' exception to the Federal Wiretap Act's statutory prohibition on using improperly intercepted communications