Mapp V Ohio Significance
What was the significance of Mapp v. Ohio?
The significance of this case was that it introduced what is called the "exclusionary rule" to the legal systems of the American states. (It had already existed on the federal level.) This is the rule that says that illegally obtained evidence (gotten without a warrant, more or less) cannot be used against a defendant in court.
The 4th Amendment protects us against illegal searches and seizures. So let's say the police illegally search your house and find evidence of crime. What can you do? Before Mapp, all you could do was complain. After Mapp, you (if you had a decent lawyer) could get that evidence excluded -- the prosecution could not use it against you in any way.
The significance is that it is part of a line of cases that enforce Bill of Rights protections to state and local governments. Specifically, the exclusionary rule of the Fourth Amendment must be followed by state and local enforcement agencies through the due process clause of the 14th Amendment. The 14th Amendment acts as a limitation on the states.
Back in the early 1800s a man sued the City of Baltimore claiming that by its actions in diverting the flows of water into baltimore harbor, the city had effectively taken his wharf without just compensation as required by the 5th Amendment. The Supreme Court through Chief Justice Marshall said that the 5th Amendment only protected him from the federal government not from the City of Baltimore. (Barron v. Baltimore)
When the 14th Amendment passed, one of its intended purposes was to incorporate the first eight Amendments as limitations upon the states. That didn't happen however. See, the Slaughter-House cases. But what the Supreme Court began to do on a case-by-case basis was incorporate specific Bill of Rights protections to the states through the 14th Amendment's due process clause. So for example in 1925 the Court in Gitlow v. New York extended the 1st Amendment freedoms of speech and the press to the states. Just this past year the Supreme Court extended the 2nd Amendment right to bear arms to the states in a case called McDonald v. Chicago. There are a few bill of rights protections that are not incorporated such as the right to indictment by grand jury and the right to bail to name just two.
What was the significance of Mapp v. Ohio?
Mapp v. Ohio requires all states to observe the exclusionary rule. The Exclusionary Rule prohibits the use of evidence or testimony obtained in violation of civil liberties and rights protected by the U.S. Constitution. Originating with the 1914 Supreme Court case of Weeks v. United States. In the Weeks case, the U.S. Supreme Court ruled that evidence against Weeks which had been obtained without a warrant was in violation of his protections under the Fourth Amendment. Initially, the exclusionary rule was only applied to federal courts. The rights guaranteed by the First Amendment (freedom of speech and freedom of association), the Fourth Amendment guaranteed the (right to privacy and search and seizure), the Fifth Amendment (self-incrimination and double jeopardy), Sixth Amendment (the right to confront witnesses) did not apply to the actions of local police or state courts.
In 1949, state courts became free to write their own rule of evidence (requirements for introducing evidence and testimony in court). Traditionally, the Supreme Court did not interfere with state courts, but with the incorporation of the exclusionary rule, the practice started to change. In 1961, in the Mapp v. Ohio the U.S. Supreme Court reversed itself and required state courts to use the exclusionary rule. Mapp v. Ohio was the first case in which the U.S. Supreme Court applied the exclusionary rule in state courts.
The facts of the Mapp v. Ohio are that Cleveland, Ohio police officers received a tip from an informant that a bombing suspect was a renter living in the home of Dolree Mapp and that evidence at her house would connect her to the numbers racket. When the police officers went to Mapp’s home and asked for the permission to search her home, she refused. The police officers returned and announced they had a search warrant. When she asked to see it, they showed her a piece of paper, which she grabbed and stuffed in her dress. The police officers forcibly retrieved their search warrant which was actually a blank piece of paper. They proceeded to search Mapp’s home without a search warrant, probable cause, or consent. They did not find the bombing suspect or the racketeering evidence, but they did find a bag of explicit books and arrested her for possession of lewd materials. Mapp was convicted in state court for possession of lewd materials. Mapp believed her Fourth Amendment rights had been violated, but when she appealed the Ohio Supreme Court upheld the conviction. She appealed to the U.S. Supreme Court, which ruled that local police officers are held accountable to the same standard as that in Weeks v. United States. Therefore, the evidence was obtained illegally was inadmissible. Mapp’s conviction was reversed.
The case became a Supreme Court landmark case, in that all state courts are required to adopt rules of evidence, which declared that evidence would be inadmissible in criminal court if it is gathered without a warrant, probable cause, or consent. The exclusionary rule is considered one of the most important doctrines in deterring police misconduct. However, there are exceptions to the exclusionary rule that allow police to conduct search and seizures without a warrant in certain situations of public safety.