Mapp v. Ohio

Mapp v. Ohio Case Brief

United States Supreme Court
367 U.S. 643 (1961)

ISSUE: May evidence obtained from an unconstitutional search and seizure be admitted against a criminal D in a state court?
HOLDING: No.
FACTS:
  • Police received info that a suspect wanted for questioning in connection w/ a bombing was in a particular house and that there was a large qty. of policy paraphernalia there too
  • Officers knocked on the door, but Mrs. Mapp denied entry b/c they didn't have a warrant
  • Police then returned 3 hours later and forcibly entered upon receiving no response from knocking
  • Mrs. Mapp was 1/2 way down the stairs when they entered and was given a supposed "warrant" that the police then forcibly took from her
  • Obscene materials were found during a search of her house and were admitted against her at trial
REASONING:
  • Wolf fact basis not controlling: The factual considerations supporting the failure of the Court inWolf to include the Weeks exclusionary rule when it recognized the enforceability of the right to privacy against the States are no longer controlling
    • Now more than 1/2 of the states to consider the issue have wholly or partly adopted the Weeksrule
    • California and other states show that other remedies have proved futile in preventing violations of the right to privacy
  • Exclusionary rule: All evidence obtained by searches and seizures in violation of the Constitution is inadmissible in state court
    • *Since the 4th Amdt. had been deemed enforceable against the States through the 14th Amdt. DPC, so is the exclusionary rule
    • Exclusionary rule is an essential ingredient of the right to privacy recognized in Wolf
    • Rule ensures that no man will be convicted on unconstitutional evidence
    • Makes good sense too, as nothing can destroy a govt. faster than its own disregard for its laws
COMMENTS:

OTHER CASES:
  • United States v. Calandra: Exclusionary rule's primary purpose is to deter future unlawful conduct and thereby effectuate the guarantee of the 4th Amdt. against unreasonable searches and seizures
    • Not designed to redress the injury to the privacy of the search victim
    • 4th Amdt. is purely deterrent of future police misconduct
  • Exclusionary rule for Miranda violations (Michigan v. Tucker): Statements obtained in violation of Mirandahad to be excluded but not the witness testimony that was obtained as a result of those illegal statements
    • Miranda requirements are only prophylactic and are not themselves required by the Constitution
    • Derivative evidence will NOT be excluded withMiranda violations

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