The United States Supreme Court
Mapp v. Ohio
367 U.S. 643 (1961)
Decided on: June 19, 1961
Issue: Whether the Fourth Amendment’s right against unreasonable search and seizure will impose the exclusionary rule in state courts as well as federal courts by suppressing illegally seized evidence when police forcibly enter a home without a warrant by breaking open the back door, where the homeowner contests the unlawful search.
Holding: Yes, the Fourth Amendment secures a person’s property, papers, and effects against unreasonable searches and seizures through the Due Process Clause of the 14th Amendment in state courts. The Supreme Court held that ‘evidence obtained by unconstitutional search was inadmissible because it violated the 4th Amendment.’ The Court imposed the exclusionary rule, which suppressed evidence because of the unlawful search and seizure and applied the exclusionary rule through the 14th Amendment. When police officers forcibly entered through the back door of a home after the homeowner protested, they violated the Constitution’s Fourth Amendment right against unreasonable search and seize and the Court held that the Exclusionary Rule is applicable in state courts.
Facts: On May 23, 1957, three police officers arrived at a defendant’s home pursuant to information that a person was hiding out who was wanted for questioning in connection with a recent bombing. It was believed that paraphernalia had been hidden in the home where Miss Mapp and her daughter lived. Upon arrival, Police officers knocked on the door and demanded to enter. Miss Mapp informed her attorney over the phone that there were police officers at her house and he advised her not to allow them inside without a search warrant. Frustrated, the three officers undertook a surveillance of the house.
Some three hours later, the officers proceeded back to her home, but this time four additional officers joined and forcibly entered through the back door breaking the screen, reaching in and allowing them inside. Miss Mapp was halfway down the stairs when she came into contact with them and demanded a search warrant. The Officer claiming he had a warrant, held up a piece of paper to show miss Mapp. She snatched it from the officer and placed it in her bra. The officer’s frisked her for the paper and as a result of this, they handcuffed her and restrained her. They brought Miss Mapp back up the stairs to her bedroom they “grabbed” and “twisted” her hand.
Disregarding her plea for help, the officers restrained defendant in her room while unlawfully searching her personal property including dressers, drawers, closets, suitcases, her child’s bedroom, kitchen, dining room and circumference of her entire home. The officers finally seized the obscene materials: four little pamphlets, a couple of photographs and a little pencil doodle, all of which were alleged to be pornographic pictures. No search warrant was ever valid or identified at trial.
Legal Analysis: Prior to this case, the Exclusionary rule was only applicable in the Federal Court system. Since the Fourth Amendment’s right against unreasonable searches and seizures has been declared enforceable against the states through the Due Process Clause of the Fourteenth Amendment, it is enforceable against them by the same sanction of exclusion as it is used against in the Federal Government. The United States Supreme Court held that the evidence was “a denial of the constitutional rights of the accused.”
Citing several cases regarding privacy acts and unreasonable searches and seizures, The Supreme Court found that law enforcement sometimes violates “the fruit of the poisonous tree” doctrine. The philosophy of each Amendment and of each freedom is complementary to, although not dependent upon, that of the other in its sphere of influence.
The Fourth and Fourteenth Amendment, protecting unreasonable searches and seizures under the Due Process Clause, is ‘A constitutional guarantee that all legal proceedings will be fair and that one will be given notice of the proceedings and an opportunity to be heard before the government acts to take away one’s life, liberty, or property. Together they assure that ‘no man is to be convicted based on unconstitutional evidence as to the States’. Rochin v. People of the State of California, 1952, 342 U.S. 165, 173, 72 S. Ct. 205, 210, 96 L.Ed. 18.
Specifically dealing with the use of the evidence unconstitutionally seized, The Fourth Amendment Under the “Weeks Rule”, says that the Fourth Amendment puts the exercise of power and authority between the United States and Federal officials under limitations and restraints and forever secure the people, their persons, houses, papers, and effects, against all unreasonable searches and seizures under the guide of the law.
“The efforts of the courts and their officials to bring the guilty to punishment, praiseworthy as they are, are not to be aided by the sacrifice of those great principles established by years of endeavor and suffering which have resulted in their embodiment in the fundamental law of the land”
Stephen Preziosi is a criminal appeals lawyer in New York City’s Times Square. His firm handles both New York Criminal Appeals and Federal Criminal Appeals throughout the nation.