Wolf v. Colorado
Wolf v. Colorado is a landmark Supreme Court case that addresses the application of the Fourth Amendment's protections against unreasonable searches and seizures at the state level. The case arose when Julius Wolf was convicted for performing illegal abortions, with evidence obtained in violation of his Fourth Amendment rights. While federal courts exclude such evidence under the exclusionary rule, the Supreme Court ruled that this rule is not a necessary component of the Fourth Amendment's protections for states. Justice Felix Frankfurter articulated that while states must respect the core rights of the Fourth Amendment, they have discretion in how to enforce these rights. The Court's decision led to the establishment of the silver platter doctrine, which allowed federal and state authorities to use illegally obtained evidence in prosecutions, a practice eventually curtailed in later rulings. The dissenting justices contended that the exclusionary rule was essential to enforce the Fourth Amendment's guarantees effectively. This case notably influenced the evolution of civil liberties and law enforcement practices within the United States.
Wolf v. Colorado
Date: June 27, 1949
Citation: 338 U.S. 25
Issues: Incorporation doctrine; exclusionary rule
Significance: The Supreme Court held that the Fourth Amendment’s freedom from unreasonable searches is binding on the states because it is fundamental to the Fourteenth Amendment’s concept of ordered liberty, but the Court also decided that state courts were not required to use the exclusionary rule.
When Julius Wolf was convicted in state court for practicing illegal abortions, the prosecution used evidence obtained contrary to the provisions of the Fourth Amendment. In a federal trial, such evidence would have been excluded from consideration by the jury, as required in Weeks v. United States (1914). Wolf’s lawyers claimed that the use of the evidence rendered his conviction invalid.
In Wolf, the Supreme Court made two rulings. First, speaking for a unanimous Court, Justice Felix Frankfurter stated that state laws must honor the Fourth Amendment’s “core” right, which is “the security of one’s privacy against arbitrary intrusion by the police.” Second, the justices decided, by a 6-3 margin, that the exclusionary rule was not “an essential ingredient” of the amendment. Frankfurter, speaking for the majority, emphasized that federalism required the Court to use restraint when placing demands on the states. He noted that other common-law countries did not employ the exclusionary rule and that there were other legitimate ways to restrain police misconduct. The dissenters, in contrast, argued that the exclusionary rule was the only effective means of giving “content to the commands of the Fourth Amendment.”
The Wolf decision gave rise to the silver platter doctrine, which often allowed federal and state prosecutors to share illegally obtained evidence for the purpose of using it in a criminal trial. The Court ended this practice in Elkins v. United States (1960) and accepted the position of the Wolf dissenters in Mapp v. Ohio (1961).