Mapp v. Ohio and Weeks v. United States: Exclusionary Rule

Mapp v. Ohio: Case Overview

Citation: 367 U.S. 643; 81 S. Ct. 1684; 6 L.Ed.2d 1081 (1961)

Facts and Procedural History of Mapp v. Ohio

Cleveland police came to Mapp's home on May 23, 1957, acting on information that a wanted person was hiding there. This individual was wanted for questioning, and police had information that not only the person but also equipment used in a recent bombing was concealed in the home. Officers demanded entry, but Miss Mapp refused, as her attorney had advised her not to allow them in without a search warrant. The officers contacted headquarters and began surveillance of the house.

Three hours later, additional officers arrived at the scene and again requested entry. Miss Mapp did not answer the door immediately, and one of her doors was then forced open by police. Her attorney arrived during this time, but officers refused to allow him inside or to see his client. Although Miss Mapp lived on the second floor, officers broke into a hallway leading to the basement. They produced a paper they claimed was a search warrant, which Miss Mapp took and placed inside her clothing. A struggle ensued between Miss Mapp and several officers, during which the paper was recovered. Miss Mapp was handcuffed on the grounds that she was being belligerent; one officer twisted her hand sharply, causing her pain. She was then led to her bedroom, where her personal papers, dresser, closets, suitcases, and other belongings were searched. Officers also searched a child's bedroom, the living room, kitchen, and dinette on the second floor. Police then proceeded to the basement, where they discovered a trunk containing obscene materials.

At trial, the prosecution was unable to produce a search warrant, and no discussion was had regarding this failure. Miss Mapp was convicted of possession of obscene materials. Questions arose as to whether a valid search warrant had ever existed, and the methods used to search her home were widely regarded as offensive to basic standards of justice. The conviction was nevertheless upheld on the grounds that the evidence had not been obtained through brutal or offensive force.

Issue: Whether the exclusionary rule established under the Fourth Amendment applies to actions taken by a state government.

Decision: The Court held that the exclusionary rule under the Fourth Amendment applies to actions taken by state governments.

Reasoning: The Court drew on several prior cases as precedent, many of which linked the Fourth and Fifth Amendments and addressed unreasonable search and seizure. The Court reasoned that the seizure of evidence in the manner employed in this case can amount to compelled self-incrimination, which may rise to the level of extortion. Precedent cases established a constitutional guarantee against unreasonable search and seizure enforceable against individual states. The Fourth Amendment's protection of the right to privacy, combined with the due process clause, was used to demonstrate how this guarantee is enforceable against the states.

Citations to Support Judgment: Weeks v. United States, 232 U.S. 383; Byars v. United States, 273 U.S. 28 (1927); Olmstead v. United States, 277 U.S. 438 (1928).

Court Decision and Reasoning in Mapp v. Ohio

Rule of Law: Criminal evidence found by the state without a lawful search warrant may not be used against the defendant.

This case was decided by a five to four vote. Those who dissented argued against this remedy and contended that the ruling effectively overturned Wolf v. Colorado, which they believed rested on sounder constitutional grounds. In their view, states should be free to make their own determinations without being subject to the exclusionary rule, as requiring strict compliance would force police to be far more cautious in gathering evidence, potentially hindering law enforcement efforts.

Citation: 232 U.S. 383, 34 S.Ct. 341, 58 L.Ed. 652 (1914)

Weeks v. United States: Case Overview

Decision: The Court found in favor of the defendant, Weeks.

Reasoning: The papers and other items taken from Weeks were seized in direct violation of his constitutional rights. When Weeks requested their return, those items should have been returned to him. The refusal to return the seized property constituted an additional violation of Weeks's rights.

Citations to Support Judgment: Boyd v. United States, 116 U.S. 616, 623 (1886); Entick v. Carrington, 19 Howell's State Trials 1029 (1765); Adams v. New York, 192 U.S. 585 (1904).