Mapp v. Ohio, 367 U.S. 643 (1961)

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FACTS ISSUE/S RULING

CASE TITLE: Mapp v. Ohio, 367 U.S. 643 (1961)


TOPIC: Exclusionary rule / “Fruit of the poisonous tree” doctrine

Police got a tip that a suspect wanted for questioning related to a Whether evidence obtained through an
bombing was hiding in Dollree Mapp’s (defendant) home. Officers unreasonable and unconstitutional No. The Supreme Court held that evidence obtained through an
forcibly entered the home without Mapp’s consent. When Mapp search and seizure admissible in state unreasonable search and seizure in violation of the Fourth
demanded to see the warrant, police showed her a piece of paper criminal trials, despite the Fourth Amendment is inadmissible in state criminal trials. The Court
purported to be a “warrant.” However, when Mapp took the Amendment's prohibition of such extended the exclusionary rule, which prevents the use of evidence
“warrant,” police engaged in a physical altercation to retrieve it searches by federal officers? obtained illegally by federal officers, to the states through the Due
from her. Process Clause of the Fourteenth Amendment.

After searching the home, the officers found and seized books and Impact: The Court cited historical cases and principles, including Boyd v.
photos that were introduced as evidence in Mapp’s criminal trial The Mapp v. Ohio decision extended the United States and Weeks v. United States, that established the Fourth
for possessing lewd and obscene materials in violation of Ohio exclusionary rule to state criminal trials, Amendment's protection of privacy against arbitrary government
state law. requiring that evidence obtained through intrusion. It emphasized that the "right of personal security, personal
unreasonable and unconstitutional liberty, and private property" are fundamental aspects of the Fourth
Mapp was convicted, even though there was no evidence that the searches be excluded from court Amendment's protections.
police ever obtained a warrant to search Mapp’s home. proceedings. This ruling reinforced the
Fourth Amendment's protections against Futher, The Court discussed the Weeks exclusionary rule, which
The Ohio Supreme Court sustained the conviction, even though it unlawful searches and seizures and prohibits the use of evidence obtained through an illegal search and
concluded there was a reasonable argument for reversal due to provided a mechanism for enforcing seizure by federal officers. It noted that this rule was an essential
the unjust manner in which the evidence was obtained. those rights in state-level cases deterrent safeguard to protect constitutional rights against
unreasonable searches.
Mapp appealed to the United States Supreme Court, claiming that
her conviction was the product of an unreasonable search and Due Process and States: The Court recognized that the Due Process
seizure. Clause of the Fourteenth Amendment made the Fourth Amendment's
protections applicable to the states. It emphasized that the right to
privacy against unreasonable searches was "implicit in the concept of
ordered liberty" and enforceable against the states.

The Court concluded that evidence obtained through unconstitutional


searches and seizures should be deemed inadmissible in both federal
and state courts. It reasoned that failing to apply the exclusionary rule
to the states would weaken the protection of constitutional rights and
incentivize disregard for those rights.

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