Mapp v. Ohio: Exclusionary Rule and Fourth Amendment Rights

Introduction: The Bill of Rights and the States

Over the centuries, there has been considerable debate about the application of the Bill of Rights to the states. A series of court cases — including Barron v. Baltimore and United States v. Cruickshank — established that the Bill of Rights was relevant only to the federal government. However, with the passage of the Fourteenth Amendment, states became obligated to follow these protections as well. This shifted the debate to whether the Bill of Rights is applicable to state and local officials.

To examine this question, this paper contrasts a fictional case with Mapp v. Ohio. The analysis covers the relevant facts of the fictional scenario, the Fruit of the Poisonous Tree Doctrine as established under Mapp v. Ohio, the applicable rules of law, and how those rules would affect the outcome of the fictional case. Together, these elements illustrate the way the Bill of Rights applies to state and local law enforcement. ("Barron V. Baltimore," 2007) ("U.S. V. Cruickshank," 2010)

Relevant and Irrelevant Facts in the Fictional Case

In the fictional case, Detective Mark Quick Draw is using a confidential informant to gather information about Sally Martin. Her address is known as a drug house, and it is believed that drug activity is occurring at the location. To confirm this, Quick Draw sends in his confidential informant. The informant returns 20 minutes later with cocaine and reports that a rectangular package is sitting in an open garbage bag alongside a number of scales. The combination of these factors gave the detective probable cause to believe that a major narcotics operation is running out of the location.

Detective Quick Draw and his team subsequently went to Judge Justice to obtain a search warrant. However, the judge was in the middle of a legal proceeding and indicated the warrant would be delayed by one hour. While waiting outside the location, Detective Quick Draw continued to observe people coming and going. After watching this activity several times, he immediately called for uniformed backup and raided the location without a warrant.

During the search, officers did not uncover evidence of a major drug operation — the package turned out to be nothing more than trash, and no scales were found anywhere. Instead, police discovered a large bag of heroin in Sally's nightstand. Sally is a convicted felon who is not permitted to possess such substances. She was subsequently charged, and her attorney filed a motion to suppress the evidence.

Rules of Law in Mapp v. Ohio: The Exclusionary Rule and Fruit of the Poisonous Tree

In Mapp v. Ohio, the U.S. Supreme Court ruled that any search must comply with the Fourth Amendment as applied to the states and local jurisdictions. This is because the Fourteenth Amendment guarantees that everyone is entitled to due process of law, making the entire Bill of Rights applicable to state actors. If any violation of the Fourth Amendment occurs — such as an illegal search and seizure — courts have the authority to correct those constitutional abuses. ("The Fourth Amendment and the Exclusionary Rule," 2012) ("Mapp V. Ohio," 2010)

The primary mechanism through which this correction occurs is the exclusionary rule. Under this doctrine, any evidence collected without a proper search warrant is inadmissible in court. This protection is enforced through a pretrial motion to suppress evidence, filed by the defendant. If a judge determines that a Fourth Amendment violation occurred, all evidence collected as a result of that violation may be excluded from trial. ("The Fourth Amendment and the Exclusionary Rule," 2012) ("Mapp V. Ohio," 2010)

Courts may also invoke the Fruit of the Poisonous Tree Doctrine. This doctrine holds that evidence derived from an illegal search — not just the directly seized evidence — is also inadmissible. For example, if police illegally obtained incriminating evidence and used it to coerce a confession, both the evidence and the confession would be excluded. The confession is considered "fruit" of the original illegal act. Together, the exclusionary rule and this doctrine give judges the tools to suppress evidence and remedy constitutional abuses by law enforcement. ("The Fourth Amendment and the Exclusionary Rule," 2012) ("Mapp V. Ohio," 2010)

Conclusion: The Supreme Court's Decision and a Judicial Ruling

The Supreme Court decided in favor of Mapp because the search was conducted illegally and the evidence collected deprived the defendant of critical protections under the Fourth Amendment. As a judge reviewing the fictional scenario, the ruling would be in favor of Sally. The heroin and any other information obtained from the illegal search would be suppressed. If the search also led to a confession or additional evidence, those too would be excluded, because the illegal search was the direct cause of their discovery. Had law enforcement not conducted the warrantless raid, none of that evidence would have been obtained.