Facts
- Cleveland police received information that a bombing suspect and illegal gambling (“policy”) materials were in Dollree Mapp’s home.
- Officers went to Mapp’s residence and demanded entry; Mapp refused and requested a search warrant after contacting her attorney.
- Police maintained surveillance and later returned with additional officers; when Mapp did not promptly admit them, officers forcibly entered.
- Mapp’s attorney arrived, but police refused to allow him to enter or speak with Mapp.
- When Mapp demanded to see a warrant, an officer displayed a paper claimed to be a warrant; Mapp grabbed it, officers recovered it after a struggle, and Mapp was handcuffed.
- Police conducted an extensive search, including a trunk in the basement; they did not find the suspect or gambling materials.
- Officers seized books, pictures, and photographs alleged to be obscene.
- Mapp was prosecuted and convicted under Ohio law for knowingly possessing lewd and lascivious materials; the state courts acknowledged the conviction relied primarily on materials seized during an unlawful search.
Issues
- Whether the Fourteenth Amendment requires state courts to exclude evidence obtained by searches and seizures that violate the Fourth Amendment.
- Whether a conviction that rests primarily on unlawfully seized evidence can stand in a state criminal prosecution.
Decision
- The U.S. Supreme Court reversed the judgment affirming Mapp’s conviction.
- The Court held that evidence obtained in violation of the Fourth Amendment is inadmissible in state criminal trials.
- The Court overruled prior precedent to the extent it allowed states to admit unconstitutionally seized evidence despite recognizing the underlying Fourth Amendment violation.
Legal Principles
- The Fourth Amendment’s protection against unreasonable searches and seizures is enforceable against the states through the Fourteenth Amendment, and that enforcement includes exclusion of unlawfully obtained evidence.
- The exclusionary rule is a required remedy in state criminal proceedings when evidence is obtained through unconstitutional searches or seizures.
- Remedies short of exclusion were deemed inadequate to deter violations and to preserve the judiciary from sanctioning unconstitutional law enforcement conduct.
Conclusion
The Court invalidated Mapp’s conviction because it was based on evidence seized during an unconstitutional search, and it made the exclusionary rule binding on state courts by requiring suppression of evidence obtained in violation of the Fourth Amendment.