Mapp v. Ohio (1961)
Name of Case
Dollree Mapp v. State of Ohio
Decided June 19, 1961
Character of Action
The case of Dollree Mapp v. State of Ohio (henceforth Mapp v. Ohio) was brought before the Supreme Court of the United States in March of 1961. The case was brought before the Supreme Court after an incident with local law enforcement and a search of Mapp's home. The defendant was initially convicted in the Cuyahoga County Ohio Court of Common Pleas. The conviction was later affirmed by the Ohio Court of Appeals, and after the affirmation by the Court of Appeals in Ohio, the case was brought before the United States Supreme Court.
Facts of the Case
The facts of the case in Mapp v. Ohio were relatively straightforward; the defendant, Dollree Mapp, was at the center of an investigation regarding a search for a potential bombing suspect. The bombing suspect was thought to be residing in Dollree Mapp's residence, which was a boarding house. The law enforcement officials in Ohio originally approached Mapp's residence and requested permission to search the residence for the bombing suspect, equipment, and gambling equipment. Mapp consulted her attorney, and declined to allow the officers to enter the residence without a search warrant.
After Mapp refused the officers admission to her residence without a warrant, officers left the premises. They returned later with a piece of paper, claiming that the document was a warrant. Mapp took the paper from the officers and tried to place the document in her dress to keep for later, per her attorney's request. However, the officers took the warrant back from Mapp, claiming that she could not have the document. They then arrested her for being "belligerent." A search of the home did not reveal the bombing suspect, equipment, or the betting equipment that the police suspected were present in the home; however, the police did uncover pornographic materials contained within a trunk in the defendant's home. The defendant claimed that the materials had been left by a previous tenant, but Mapp was arrested, charged, prosecuted, and found guilty by the Cuyahoga County Ohio Court for possession of pornographic or obscene materials. Mapp's attorney challenged the ruling, first in the Ohio appellate courts, then later in the Supreme Court of the United States.
Are materials or evidence gathered in a search conducted in violation of the Fourth Amendment to the Bill of Rights admissible in state court? Mapp's attorney also asked the Supreme Court to determine whether the materials gathered were protected by the First Amendment. However, the Supreme Court declined to answer the second question due to the legal reasoning of the first.
Decision of the lower courts
Mapp was initially convicted of the possession of pornographic or obscene materials in the Cuyahoga County Ohio Court of Common Pleas. The conviction was later affirmed by the Ohio Court of Appeals, and after the affirmation by the Court of Appeals in Ohio.
Decision of the Supreme Court
The Supreme Court of the United States determined that Mapp's Fourth Amendment rights had been violated, and that the evidence gathered in an illegal search and used for prosecution in a state criminal trial were indeed "fruit from the poisonous tree."
The majority opinion, written by Justice Clark, states that all evidence obtained in an illegal search cannot be used as evidence in a state criminal trial. Justice Clark notes that the search that was done was clearly unconstitutional, and declined to answer the First Amendment question proposed by the petitioner, as the legality of the evidence was a non-issue to the case-- the petitioner's rights had been violated by the search, and anything that was turned up over the course of that search was "fruit of the poisonous tree." Clark also notes that the Fourteenth Amendment guarantees that the individual will be protected from the state in cases like this, as it is the Fourteenth Amendment that extends Constitutional protections that the individual enjoys to from the federal level to the state level.
The concurring opinions in this case, written by Justices Black and Douglas, note that in the years since Wolf v. Colorado (1949) there was a lack of coherence between state laws in regards to the exclusionary rule and evidence obtained illegally or unconstitutionally. While some states adopted the exclusionary rule, others did not; Black and Douglas felt that the Mapp v. Ohio case was an excellent way to tie together the abnormalities caused by the (according to Justices Black and Douglas) poorly-considered opinion and precedent of Wolf v. Colorado (1949). Black also notes that there is a close link between the Fourth and Fifth Amendments, foreshadowing the Warren Court's dedication to revamping the criminal justice system based on the Constitution's Bill of Rights.
The majority opinion was a controversial one. For the first time, the Court gave power to the individual, rather than to the government; although this decision marked a change in the way criminal law and individual rights were approached by the Supreme Court. Justice Harlan dissented in this case, noting that many states do not use the exclusionary rule (the rule that excludes illegally-seized evidence as the result of the "fruit of the poisonous tree"), and that they should be constitutionally free to choose whether or not they wish to follow the exclusionary rule in their own districts.
From a legal perspective, it makes much more sense to apply constitutional rules to the states than to allow states to make their own rules. If the federal government is going to be held to a certain standard for law, then states should be held to the same standard, especially insofar as individual rights are concerned.
Principle of Law
The exclusionary rule now applies to the states, and the Fourth Amendment also applies to the states; states must adhere to the rules and precedents of the Fourth Amendment, and cannot use illegally-seized evidence to convict citizens of crimes. This case overruled the precedent set in Wolf v. Colorado (1949) and foreshadowed the changes to the criminal justice system that would occur.
Unknown. "Mapp v. Ohio - 367 U.S. 643 (1961)." Justia US Supreme Court Center, 2014. Web. 24 Jan 2014.