Case Brief: Mapp v. Ohio

Facts
Some Cleveland police officers arrived in the home of the appellant, Miss Mapp, looking for a bombing suspect. The appellant told the officers they could not enter the home until they showed her a search warrant, but they forcibly entered without ever procuring a warrant. The officers then found and the State of Ohio subsequently prosecuted the appellant for possessing “certain lewd and lascivious books, pictures, and photographs.” The Ohio Common Pleas Court convicted the appellant for possessing this material, even though it conceded that the material had been seized unlawfully; this judgment was upheld by the Ohio Supreme Court.

Question Presented
The US Supreme Court reviewed whether it had the right to require state governments to enforce the exclusionary rule, which prohibited prosecutors from using evidence that had been obtained through illegal searches and seizures. In Weeks v. United States, the Court had ruled that the exclusionary rule applied in federal prosecutions, but in a later case, Wolf v. People of Colorado, the Court ruled that the Fourteenth Amendment did not require states to adhere to the rule.

Holding
The Court ruled that the Weeks decision must also be applied at the state level. In other words, the Court ruled that any evidence obtained through searches and seizures in violation of the Fourth Amendment could not be admissible in state courts.

Rationale
The Court pointed out that the Wolf Court had upheld the Weeks judgment that the Fourteenth Amendment required states to adhere to the Fourth Amendment’s guarantee of privacy. The Wolf Court based its argument that the exclusionary rule could not be imposed on the stations because of two main “factual considerations”: most states opposed the exclusionary rule, and there were supposedly other means of protecting Fourth Amendment rights. The Mapp Court pointed out that most states now supported the exclusionary rule in whole or in part and that time had shown that the other means of protecting Fourth Amendment rights were insufficient. The Mapp Court further argued that if the exclusionary rule was guaranteed by the Fourth Amendment, and if, as the Wolf Court had declared, the Fourteenth Amendment required the states to uphold the privacy guarantees of the Fourth Amendment, then it followed that states were required to adhere to the exclusionary rule.

Dissent

The dissenting justices argued that the Court’s decision did not properly respect precedent and that it violated the right of states to make their own laws. They further argued that the exclusionary rule was not part of the Fourth Amendment but establish by Weeks in order to better enforce the privacy clause of that amendment; consequently, the constitutional argument made by the majority in Mapp failed. The dissenting justices also disputed the “factual considerations” made by the majority, writing that half of the states still did not adhere to the exclusionary rule and that, even though many states were not taking actions to safeguard the Fourth Amendment as quickly as many desired, the answer was patience, not coercion.