Mapp v. Ohio
**Mapp v. Ohio Overview**
Mapp v. Ohio is a landmark Supreme Court case decided in 1961 that significantly impacted the application of the Fourth Amendment, which protects against unreasonable searches and seizures. The case arose when police officers, who did not present a warrant, illegally searched the home of Dolly Mapp in Cleveland, Ohio, under the pretense of looking for gambling materials and a fugitive. Although they found nothing pertaining to their search, they discovered and used pornographic materials as evidence to convict Mapp.
Prior to Mapp v. Ohio, while the Supreme Court had ruled that evidence obtained unconstitutionally was inadmissible in federal courts (as established in Weeks v. United States), this exclusionary rule did not apply to state courts. Mapp's case challenged this precedent, leading the Supreme Court to rule that the exclusionary rule also applies to state courts, thereby reinforcing citizens' rights against unlawful searches. This decision established that the legality of evidence must be upheld for the protection of individuals, marking a significant expansion of civil liberties in the United States. The ruling highlighted the necessity of the exclusionary rule as a deterrent against police misconduct and emphasized the role of law in maintaining justice, even in the context of criminal prosecution.
Mapp v. Ohio
Date: June 19, 1961
Citation: 367 US 643
Issue(s): Search and seizure; exclusionary rule
Significance: In this landmark decision, the Supreme Court held that the exclusionary rule was binding on the states whenever evidence was obtained in an unreasonable search and seizure, thereby completing the “incorporation” of the Fourth Amendment into the due process clause of the Fourteenth Amendment.
In an earlier landmark case, Weeks v. United States (1914), the Supreme Court held that evidence obtained contrary to the principles of the Fourth Amendment would be inadmissible in federal criminal trials. The purpose of this controversial exclusionary rule was to protect people from police misconduct. Since the Fourth Amendment was not binding on the states at that time, the ruling had no impact on state trials, in which most criminal prosecutions took place.
In another landmark case, Wolf v. Colorado (1949), the Court unanimously required that the states must respect the “core” principle of the Fourth Amendment, which is freedom from unreasonable searches and seizures. By a 6–3 vote, however, the Court also held that the exclusionary rule was not binding on the states because it was not “an essential ingredient” of the amendment. The decision resulted in the so-called “silver platter doctrine,” which permitted federal prosecutors to use evidence obtained illegally by the states, until 1960.
Seven police officers, claiming to have a warrant but never showing it, broke into the home of Dolly Mapp in Cleveland, Ohio. An informant had told them that they would find gambling paraphernalia and a fugitive wanted for a recent bombing. Although they found neither, they did find pornographic books and magazines. These items were used as evidence to convict Mapp of possessing illegal pornographic materials. Ohio’s high court concluded that the incriminating evidence had been obtained illegally, but while referring to Wolf, it nevertheless allowed the evidence to be used. When the case was appealed to the US Supreme Court, an amicus brief of the American Civil Liberties Union advocated that Wolf be overturned, although Mapp’s attorney argued the case entirely on the issue of obscenity.
The majority of the justices decided to ignore the less important obscenity question. Five justices agreed that the exclusionary rule should be applied to the states. Speaking for the five, Justice Tom C. Clark referred to the rule as a “deterrent safeguard,” without which the right might exist in theory, but not in reality. Observing that half of the sates already had adopted the exclusionary rule, he wrote that there were no other practical means to prevent the police from conducting unreasonable searches. Concerning an earlier justice’s complaint, “the criminal is to go free because the constable has blundered,” he answered, “The criminal goes free if he must, but it is the law that sets him free.” Justice Potter Stewart refused to join the majority because he wanted to base the decision on the First Amendment. The three dissenters rejected the incorporation doctrine, which in their view intruded upon the states’ sovereignty.
Bibliography
Long, Carolyn, and Renee Hutchins. "Supreme Court Landmark Case Mapp v. Ohio." C-SPAN. Natl. Cable Satellite Corp., 30 Nov. 2015. Web. 12 Jan. 2016.
Martinez, J. Michael. "Mapp v. Ohio (1961) and the Exclusionary Rule Redux." The Greatest Criminal Cases: Changing the Course of American Law. Santa Barbara: Praeger, 2014. 75–98. Print.
McInnis, Thomas N. The Evolution of the Fourth Amendment. Lanham: Lexington, 2009. Print.
Wohl, Alexander. "Mapp v. Ohio Turns 50." Slate. Slate Group, 7 June 2011. Web. 12 Jan. 2016.