Mapp V. Ohio (1961)

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Background/Intro- One of the most significant supreme court cases was Mapp v. Ohio. It all commenced on May 23, 1957, when the Police of Cleveland, Ohio, concluded that Dollree Mapp was harboring a suspected bomber in her residence and demanded entry. Mapp refused to admit them in unless they possessed a warrant. The officers did not obtain a warrant. A few hours later, more officers arrived and forced their way into her house. One officer held up a document and presented a fake warrant to her, Mapp wasn't convinced so the officers handcuffed her and then started the search. They did not detect the man they were looking for, but they did find what they said were sexually explicit materials. Mapp was arrested for possessing the photographs and was convicted in an Ohio court. The defendant claimed that the materials had been left by a previous tenant, but Mapp was arrested, charged prosecuted, and found guilty by the Cuyahoga County Ohio Court for possession of pornographic/obscene materials. Mapp's attorney challenged the ruling, first in the Ohio appellate courts, then later in the Supreme Court of the United States.

Argument 1- Although the police officers did not search her with a warrant, Dollree Mapp is a criminal. Direct evidence was found revealing that she owned pornography which was illegal at the time. The police also had the authority to search her house since they suspected that there was a bomber hiding in her residence. If the reason is rationable enough, then the officers don't need to possess a search warrant since warrants aren't always required. In addition, a previous supreme court case, Weeks v. United states, had created the exclusionary rule which only applied to federal courts. Mapp's case is not a federal case but a state case which means the exclusionary rule does not apply to this case. The court has all the evidence to prove that Mapp is a criminal and all the evidence obtained is legal.

Argument 2- Dollree Mapp shouldn't be charged as a criminal. The officers did not have a search warrant making all the evidence obtained illegal. They also did not find the bomber which the so-called warrant was for but yet they arrested her. This violates her fourth amendment rights. Which should protect her from unlawful searches and seizures meaning that the police can't search her house without a warrant or probable cause. Another amendment, it violated was Mapp's first amendment rights since they had a law against the possession of obscene material.The cause of the search also wasn't reasonable. They didn't have a valid explanation,to actually search her house, the police officers, in fact, weren't even sure if Mapp was hiding a criminal, they were just assuming she was.

Decision- The U.S. Supreme Court ruled in a 5-3 vote in favor of Mapp. However, they chose to ignore the question of whether a law against the possession of obscene material violated Mapp's  right to freedom of expression as explained in the First Amendment. As Justice Tom C. Clark wrote, "Since the Fourth Amendment's right of privacy has been declared enforceable against the States through the Due Process Clause of the Fourteenth, it is enforceable against them by the same sanction of exclusion as is used against the Federal Government. Were it otherwise, then, just as without the Weeks rule the assurance against unreasonable federal searches and seizures would be "a form of words," valueless and undeserving of mention in a perpetual charter of inestimable human liberties, so too, without that rule, the freedom from state invasions of privacy would be so ephemeral and so neatly severed from its conceptual nexus with the freedom from all brutish means of coercing evidence as not to merit this Court's high regard as a freedom "implicit in the concept of ordered liberty." Basically, evidence seized unlawfully, without a search warrant, could not be used in criminal prosecutions in state courts. As stated in the quote, the search violated Mapp's fourth amendment rights and is viewed as unconstitutional. The decision also launched the Court on a troubled course of determining how and when to apply the exclusionary rule.

Impact/Conclusion- Mapp V. Ohio impacted the United States in multiple different ways. Because of this case, the requirement for ensuring that evidence was legally obtained was placed on the court. This decision opened up the court to a number of difficult cases concerning how to apply the exclusionary rule. It changed a few guidelines of the exclusionary rule. A previous case, Weeks v. United States, was the actual case that formed the exclusionary rule but Mapp V. Ohio took it further to state courts since, Weeks v. United States only covered federal cases. Both cases did similar things but Mapp V. Ohio had a wider range. Basically, now, the exclusionary rule is available in state courts along with federal courts. It protected and still protects people against unnecessary search and seizure. It established innocence before guilt. It also stopped the manufacturing of false evidence which was a considerable issue before the case. However, it did make the jobs of the police harder since, now officers need to follow the exclusionary rule more rigorously and need more reasonable causes to search someone/something. It also occasionally allows guilty people to go free, following 1962, crime rates began to rise quickly as compared to the crime rates of those cities that already excluded unlawfully obtained evidence, an effect that continued to increase over time. This impacts all the citizens in America making it less of a safe environment. It also added cost to the criminal justice system. In addition, the case itself acted as a precedent to many other cases. Such cases include Chimel v. California and Katz v. United States.This is how Mapp V. Ohio impacted the United States of America and how it came to be. 

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⏰ Last updated: Feb 24, 2018 ⏰

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