Case Brief Mapp v Ohio

Mapp v. Ohio, 367 U.S. 643, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961) Parties Mapp (Petitioner) vs. Ohio (Respondent) Procedure Ohio Supreme Court affirmed conviction (petitioner lost) United States Supreme Court ruled that evidence obtained in violation of the Constitutional right against searches and seizures is inadmissible in any court of law (petitioner won) Facts On May 23, 1957 three Cleveland officers forcibly opened at least one door of Mapp’s residence after she denied entry without a search warrant under advice of her lawyer. When Mapp’s attorney arrived at the scene, he was not allowed to see Mapp or enter the house. Mapp demanded a search warrant from officers and was presented with a piece of paper that she took and hid on her person; officers recovered the piece of paper from her, placed her in handcuffs, and claimed she was belligerent. Officers searched her bedroom with her present, including drawers, dresser, closet, and suitcases; after searching her room, they moved to the downstairs and basement, where officers discovered obscene materials. The materials discovered during this search were what she was convicted for. No search warrant was provided at her trial, and the absence of a search warrant was not explained. Issue Were the obscene materials protected from seizure by the Fourth Amendment? Should the exclusionary rule apply to state courts? Rule All evidence obtained by searches and seizures in violation of the Fourth Amendment is inadmissible in a state court. Application The United States Supreme Court used the Fourth Amendment right of privacy and the Due Process Clause of the Fourteenth Amendment to say that the right to privacy, including the right against unreasonable searches and seizures, applies to states. The State used Wolf v. Colorado as a precedent, which concluded that the State is not prevented from using unconstitutionally seized evidence at trial. Justice Black said that the Fourth Amendment’s right against unreasonable search and seizure combined with the Fifth Amendment’s right against self-incrimination justifies and requires the exclusionary rule. The United States Supreme Court referenced the exclusionary rule presented in Weeks v. United States that stated evidence seized by law enforcement during an unconstitutional search or seizure must be excluded from a criminal trial. United States Supreme Court also referenced Elkins v. United States, where it was ruled that the “silver platter doctrine” allowing federal prosecutors to use evidence illegally gathered by state police to be a violation of the Fourth Amendment. United States Supreme Court also referred to Rea v. United States, where it was determined that the state could not use evidence illegally obtained by federal agents in their trials. The Supreme Court also brings into account that a coerced confession is not admissible into evidence and is constitutionally invalid, therefore illegally obtained evidence should be as well. Mapp’s case violated the rule announced because the evidence was obtained unconstitutionally and used against Mapp in court. Mapp’s case also went against the Fourth and Fourteenth Amendments against unreasonable searches and seizures applying to states via the Due Process Clause. The exclusionary rule was also violated in Mapp’s case, as the items she was convicted for having were found during a search that happened without a warrant or reasonable cause. Conclusion The United States Supreme Court found in favor of the petitioner, Mapp, in that the Fourth and Fourteenth Amendment guarantee a right against the use of evidence in trials that was gained during unconstitutional searches and seizures. This sets a precedent for all other cases involving searches and seizures and requires a warrant or reasonable suspicion for state authorities to enter a house and collect evidence or materials to be used in a trial. Discussion Mapp v. Ohio was a 6-3 decision where the majority declared all evidence obtained by unconstitutional searches and seizures under the Fourth Amendment is inadmissible in a state court. Justice Harlan, Frankfurter, and Whittaker were the dissenting opinion, and Justice Stewert concurred in judgement but had no view on the constitutional issue. The dissenting opinion questioned whether the states were constitutionally free to follow the exclusionary rule based on their own discretion. They believed that forcing the exclusionary rule on states would mess up the balance between state and federal responsibility, and that states have their own problems in criminal law. The dissenting opinion also said that the Supreme Court has refused to reverse state convictions based on illegally obtained statements, which were are also a violation of Constitutional Amendments as the majority opinion had said. The dissenting opinion believes that forcing the exclusionary rule on states is a way of punishing police rather than the fairness in judicial proceedings. The ruling of this case is good for society and the people, as it protects them from potential unconstitutional activities of the police, as well as potential bias and unfairness in court. This ruling should also be good for law enforcement, as it holds them accountable for their actions and requires that every search and seizure must follow proper proceedings. It is good for the court system because it ensures fair trials and less cases going to superior courts for unconstitutional seizures of evidence. The exclusionary rule is necessary because it ensures that all evidence put into trial for all state and federal cases was obtained legally and with a warrant or reasonable suspicion. On the trail to equality, this is important for all people because it helps to ensure a fair trial to everyone regardless of background, race, socioeconomic status, etc. It is also necessary to deter police misconduct. However, there are drawbacks to the use of the exclusionary rule, including the freedom of the guilty because of mishandling by the police and the extension of trial times and costs due to the fight over consideration of evidence by attorneys from both parties. There is no evidence saying that the exclusionary rule deters police misconduct, and many scholars claim the opposite. Some states had adopted the exclusionary rule previously to this case because all other ways to protect the Fourth Amendment had failed, so this ruling did not have the widespread effect that it was made to seem. In this case, the Supreme Court expanded upon a judicial rule that is not in the Constitution. Some would argue that this is not okay, as the Supreme Court is meant to interpret the Constitution as it is, rather than create new rules. However, the Supreme Court put the Fourth and Fourteenth Amendments together to create and defend the exclusionary rule, which means that it indirectly came from the United States Constitution and was a part of their interpretation, which makes it okay. It is a necessary rule to defend the Fourth Amendment against unreasonable searches and seizures and keep police misconduct in line and was adopted for the proper reasons. This ruling conflicts with the Terry Stop Rule that was created out of Terry v. Ohio, stating that a police officer has the right to briefly stop and detain a person for a pat-down search if they have reasonable suspicion that a person is armed, engaged, or about to be engaged in criminal conduct. Whereas this ruling is defending the people against unreasonable searches and seizures, the Terry Stop Rule is encouraging the police to search people and seize what they find based on nothing more than suspicion, much of which is rooted in race and stereotypes, as has been discovered over the years. In 2011, the New York District Court found that the New York stopand-frisk policy, adapted and adopted from the Terry Stop Rule, violated the Fourth Amendment because it made stop and frisks more frequent for people of color. As there is no handbook for what can qualify as suspicious behavior, it is up to the judgement of law enforcement to determine who looks like they are armed, committing a crime, or about to commit a crime, much of which is influenced by preconceived subconscious biases.