The U. S. Supreme Court Case of Mapp v. Ohio was a turning point in criminal justice. In this landmark case, Fourth Amendment protections were incorporated into the Due Process Clause of the Fourteenth Amendment. This case, among others, evaluated the role of the Fourteenth Amendment and its application to the State judicial systems. There have been some modifications to the rule since the Mapp case decision in 1961.
Mapp v. Ohio
Mapp v. Ohio was a landmark court case in 1961 where the U.
S. Supreme Court ruled that the evidence obtained through illegal searches and seizures by state officers may not be admitted into criminal trials. The ultimate issue for the Court to decide was; can evidence obtained through a search that violated the Fourth Amendment be admissible in state criminal proceedings? Looking through the background, the effects, and the current activity of the courts will help break down the significance of this case.
This case evolved in Cleveland, Ohio with a woman named Dollree Mapp.
On May 23, 1957, police officers gained information that a bombing suspect, as well as illegal betting equipment, could possibly be found and the Mapp residence. Three police officers went to the residence and asked her permission to come into the house, Dollree refused them without a search warrant. Two officers left, while one stayed. After a few hours the two officers that had left returned with several more officers. Waving a piece of paper around they proceeded to break the door down. Mapp asked to see the “warrant” and took it from the officer and stuffed it in her dress. The officers began to struggle with her in attempts to get the “warrant” back. They put handcuffs on her for being belligerent. During the search of the residence the police found neither the bombing suspect nor any types of illegal betting equipment.
However, they did produce pornographic material in a suitcase in close proximity to Mapps bed. She was arrested, prosecuted, and was found to be guilty, and sentenced for the pornographic material. No search warrant was ever produced or introduced as evidence in her trial (Mapp v. Ohio, 1961). She appealed and eventually the case made its way to the Supreme Court. During this time the Federal Government prohibited evidence gathered with warrantless searches, this standard was in effect from the Court’s decision in Weeks v. U.S., (1914).
The U. S. Supreme Court ruled and reversed Mapp’s conviction. The ruling in Mapp overturned the ruling applied in the case of Wolf v. Colorado and applied the exclusionary rule to the states. The U.S. Supreme Court unmistakably states in “Since the Fourth Amendment’s right of privacy has been declared enforceable against the States through the Due Process Clause of the Fourteenth; it is enforceable against them by the same sanction of exclusion as is used against the Federal Government (Mapp v. Ohio, 1961).” The Due Process Clause is the means by which the Bill of Rights has become binding on state governments as well as on the federal government.
Although Mapp was a landmark case, there are other cases that applied to the rights of citizens and established a set of criteria for actors in the criminal justice system. In Weeks v. United States (1914), the case of Freemont Weeks, involved being arrested without a warrant in his place of employment. Meanwhile, officers had gone to the defendant house, and a neighbor told police where a key to the house was kept, they retrieved the key and entered the house. The officers searched his room and took into possession a variety of papers found, the documents were turned over to the United States marshal. The marshal and officers returned to the house later that day to locate any additional evidence. They were let into the house by possible boarder, and they retrieved letters and envelopes. Neither the marshal nor the officers had a search warrant for the premises (Weeks v. U.S., 1914).
The U.S. Supreme Court reversed the ruling stating: “The record shows that what they did by way of arrest and search and seizure was done before the finding of the indictment in the Federal court; under what supposed right or authority does not appear. What remedies the defendant may have against them we need not inquire, as the 4th Amendment is not directed to individual misconduct of such officials. Its limitations reach the Federal government and its agencies (Weeks v. U.S., 1914). ” The exclusionary rule, as applied in Weeks v. U.S., prevents federal law enforcement officers from using evidence at a trial that is obtained through an illegal search or seizure, but is not forced upon the States. The evidence was deemed inadmissible because a federal agent seized property without the legalities in place. The next major case to address an application of the exclusionary rule to the states was Wolf v. Colorado (1949).
In the case of Wolf, the U. S. Supreme Court affirmed the decision of the Supreme Court of Colorado to let stand Wolf’s conviction on the ground that, although the Fourth Amendment applied to the states, the states were not required to exclude evidence obtained unlawfully (Wolf v. Colorado, 1949). In other words the Fourth Amendment was applied to the states through Due Process Clause of the Fourteenth Amendment though the exclusionary rule was not. This lead the Silver Platter Doctrine, where “evidence obtained by state agencies in unreasonable search and seizure was admissible in a federal criminal trial, where no federal agent participated in the search or seizure and the state officers did not act solely on behalf of the United States (University, 1999).” This doctrine was overruled in the case of Elkins v. United States (1960). A year later, the Supreme Courts made the exclusionary rule binding on all state court systems, in the cases of Mapp v. Ohio (1961).
The cases mentioned laid the ground work for the system as it is today and changed how police officials can gather evidence for prosecution against criminals. Defenders of the exclusionary rule express the ability of the courts to know when it was in “good faith” and when gathering evidence was purposely done unconstitutionally. United States v. Leon (1984) was the turning point for the exclusionary rule and the beginning of the exceptions to the rule. In Leon, the invalid warrant signed by a magistrate was the cause for the ruling. Officers had gotten a search warrant, but a later review determined the warrant to be facially invalid. The Court held that excluding evidence should not apply because the police relied on “good faith” on the legality of the warrant: the evidence was admitted into trial. More recently was the case of Herring v. United States (2009), in which an error in record keeping caused an illegal search and seizure.
Herring took the issue to the Supreme Court. Chief Justice Roberts affirmed in a 5-4 ruling: “To trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningfully deter it, and sufficiently culpable that such deterrence is worth the price paid by the justice system (United States v. Leon, 1984, p. 907).” Another exception to the exclusionary rule is the inevitable discovery rule, which applies to an illegal search and seizure to get evidence that would eventually be found through police investigation.
The discovery rule was established in the case of Nix v. Williams (1984) and the U.S. Supreme Court held “Although the independent source doctrine does not apply here, its rationale is wholly consistent with and justifies adoption of the ultimate or inevitable discovery exception to the exclusionary rule. If the prosecution can establish by a preponderance of the evidence that the information ultimately or inevitably would have been discovered by lawful means – here the volunteers’ search – then the deterrence rationale has so little basis that the evidence should be received (Nix v. Williams, 1984, pp. 441-444).” The good faith exception and the discovery rule have been considered a harmless violation of defendants constitutional rights compared to allowing the defendant to go free.
The ruling in Mapp v Ohio has had significant meaning to the criminal justice fields. The exclusionary rule does affect the work of law enforcement by restricting the action that they may take in performing an investigation. This may add to a cost factor because obtaining more evidence to get a warrant will add up on manpower and time. The Court put this in rule in place to deter police misconduct, I would interpret this is: good police work will win in the end. As for the courts, they are affected by what they have brought before them from the individuals who gather the evidence. The courts are involved with a checking process to be fair and to ensure that all individuals’ rights are protected. Therefore, the costs to the court are the costs of losing cases at trial due to the violations made against individual’s rights.
The Mapp case was historically important to the criminal justice arena. Incorporation of the exclusionary rule resulted in a requirement that state and local police to comply with Fourth Amendment standards in regards to searches and seizures. This case has refined the laws of admissibility of evidence and the procedures that law enforcement must follow.
Weeks v. U.S., 232 U.S. 383 (U.S. Supreme Court February 24, 1914). Wolf v. Colorado, 338 U.S. 25 (U. S. Supreme Court June 27, 1949). Elkins v. United States, 364 U.S. 206 (U.S. Supreme Court June 27, 1960). Mapp v. Ohio, 367 U.S. 643 (U.S. Supreme Court June 19, 1961). Nix v. Williams, U.S. Supreme Court (467 U.S. 431 June 11, 1984). United States v. Leon, 468 U.S. 897 (U.S. Supreme Court 1984). Herring v United States, 07-513 (Supreme Court of the United States January 14, 2009). University, C. S. (1999, January 16). Silver Platter Doctorine-or Standing Idly By. Retrieved March 2, 2012, from From the Incident through the System Legally: Knowledge Base of Legal Concepts: http://www.csudh.edu/dearhabermas/silvplat.htm