2. MAPP v. OHIO 367 U.S. 643, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961)
Facts: Police got a tip that a suspect wanted for questioning related to a bombing was hiding in Dollree Mapp’s (defendant) home. Officers forcibly entered the home without Mapp’s consent. When Mapp demanded to see the warrant, police showed her a piece of paper purported to be a “warrant.” However, when Mapp took the “warrant,” police engaged in a physical altercation to retrieve it from her. After searching the home, the officers found and seized books and photos that were introduced as evidence in Mapp’s criminal trial for possessing lewd and obscene materials in violation of Ohio state law. Mapp was convicted, even though there was no evidence that the police ever obtained a warrant to search Mapp’s home. The Ohio Supreme Court sustained the conviction, even though it concluded there was a reasonable argument for reversal due to the unjust manner in which the evidence was obtained. Mapp appealed to the United States Supreme Court, claiming that her conviction was the product of an unreasonable search and seizure.
Issue: whether evidence obtained through an illegal search and seizure by state officials is admissible in a state prosecution. Specifically, the case examined whether the exclusionary rule, which prohibits the use of illegally obtained evidence, applies to state courts through the Due Process Clause of the Fourteenth Amendment.
Rule:
The exclusionary rule, established in Weeks v. United States (1914), dictates that evidence obtained in violation of the Fourth Amendment cannot be used in federal courts. The rule serves as a deterrent against unlawful searches and seizures by law enforcement officials.
The Court in Wolf v. Colorado (1949) recognized the right to privacy and protection against arbitrary police intrusion as fundamental, applying the Fourth Amendment to the states via the Fourteenth Amendment. However, Wolf did not extend the exclusionary rule to state courts.
Application:
In Mapp v. Ohio, police officers forcibly entered Dollree Mapp’s home without a valid search warrant and seized lewd and lascivious materials, which led to her conviction. The search and seizure were conducted in blatant disregard for Mapp’s Fourth Amendment rights. The trial court admitted the unlawfully obtained evidence, resulting in her conviction.
The Supreme Court of Ohio upheld Mapp's conviction despite acknowledging that the evidence was obtained unlawfully. This decision highlighted the inconsistency in applying constitutional protections against unreasonable searches and seizures solely to federal, but not state, prosecutions.
In its analysis, the U.S. Supreme Court revisited the principles set forth in Boyd v. United States and Weeks v. United States, reaffirming that the Fourth Amendment’s protections are fundamental rights enforceable against the states through the Fourteenth Amendment. The Court emphasized that without the exclusionary rule, the Fourth Amendment would be reduced to a mere formality, unable to provide practical protection against unlawful state actions.
The Court also considered the practical and constitutional implications of allowing state courts to admit evidence obtained in violation of the Fourth Amendment. It noted that without a uniform application of the exclusionary rule, federal and state cooperation in law enforcement would be compromised, encouraging federal officers to bypass constitutional requirements by colluding with state officials.
Conclusion: The Supreme Court ruled that the exclusionary rule applies to state courts through the Due Process Clause of the Fourteenth Amendment. Therefore, evidence obtained through an unconstitutional search and seizure is inadmissible in state prosecutions. This decision overturned the precedent set by Wolf v. Colorado and mandated that both state and federal courts adhere to the same constitutional standards regarding the exclusion of illegally obtained evidence. Consequently, the Court reversed Mapp's conviction, reinforcing the essential protection of individual rights against unlawful searches and seizures.
Key Takeaways:
1. A warrantless search and seizure process is a violation of the Fourth Amendment right to privacy.
2. Exclusion of evidence gathered through a warrantless search and seizure process under the exclusionary rule is required under the Due Process Clause. That is, the Due Process Clause allows for enforcement of the right to privacy through exclusion of evidence.