Mapp v. Ohio (1961) – FYS 100 – 34: The Rights of the Criminally Accused

Dollree Mapp was a resident of Cleveland, Ohio whom police officers believed was harboring a fugitive. In 1957, police officers approached Mapp’s home in attempt to complete a search for the fugitive, but without a warrant the officers were denied entry by Mapp. Three hours, the officers forced into Mapp’s home with a paper claimed to be a search warrant and completed the search. The police did not find any evidence of a fugitive, but they did find scandalous photos in Mapp’s possession, which were illegal to posses in Ohio at the time. At trial the prosecution did not provide a valid warrant nor explanation for the lack of warrant, however, Mapp was found guilty and sent to prison.

In a breakdown of 6 to 5, the Court reversed and remanded the state of Ohio’s ruling on the case. In his opinion, Justice Clark described that the majority’s main reason for reversing the ruling was because of the exclusion doctrine established with the Weeks v. United States (1914) case which stated that evidence obtained unconstitutionally could not be used in the court of law. Being that the Ohio police found the scandalous photos through an unconstitutional search, Mapp could not be prosecuted for the charges. Contrary to the majority opinion, Justice Harlan wrote a dissenting opinion which used the ruling of the Wolf v. Colorado (1949) case to argue that because the Constitution did not explicitly describe the exclusion doctrine as it pertains to the Fourth Amendment, the doctrine was not required to be used by the states.

What I find interesting about this case is that it serves as yet another example of the constant struggle between federal and state power. The United States was founded by people who wanted to escape the oppressive rule of an ultimate ruler, while still understanding that a basic level of uniformity was required to form a cohesive country. Balancing the power between federal and state government was an inevitable and unavoidable situation formed by the creation of this country. The Mapp v. Ohio (1961) case sheds light on the delicate balance of power because although the federal government, the U.S. Supreme Court in this case, ruled that the exclusion doctrine was essential in the Weeks v. United States (1914) case, the states still had the freedom to decide whether or not to enforce the doctrine such as in the Wolf v. Colorado (1949) case. The Mapp v. Ohio (1961) case may have begun as an ordinary Fourth Amendment case, however, the case became a symbol of the federal government’s ability to serve as an ultimate power in specific aspects of government.

Sydney Gardner says:

October 24, 2016 at 6:06 pm

I found this case to be interesting because it is very similar to a lot of cases we have studied. It is similar in the fact that police officers searching and seizing something without a warrant. I found it interesting how the officers claimed to have a search warrant and searched the house for a fugitive that wasn’t found, and arrested Mapp for a completely separate crime. The vote break down of the case was 6-3, meaning that not all the Justices agreed with the exclusionary doctrine that was established in this case.
I think its important to note that the exclusionary doctrine limits the power that police officers have. Allowing them to search and seize without a warrant and use the evidence in Court would give them too much power. I think its important that you mentioned the struggle between the State and Federal government, because the State rules do not always apply to the ruling of the Federal government. So while the state of Ohio ruled that Mapp could be arrested without a proper warrant, the Federal government disagreed.

Kurt Linke says:

October 24, 2016 at 8:43 pm

Sydney touches on a lot of the important points in this case. The tension between the Supreme and state courts are of extreme importance because it’s also worth noting how much flexibility the Supreme Court has in determining what they hear and what they rule on. When the case was brought to the Supreme Court, Mapp’s lawyers tried to do so on First Amendment grounds, and the Supreme Court based their ruling off the Fourth Amendment. Their ruling and decisions highlight the important issues in the case Sydney touched on, such as the lack of solid evidence against Mapp in the first place, the faulty warrant, and the mis-justice that occurred in the trial. The ruling based off the two previous cases, Weeks v. United States and Wolf v. Colorado, is also important to note because Mapp v. Ohio, because Mapp v. Ohio clarified the previously constructed language by clearly stating that evidence not explicitly mentioned in the warrant was not admissible in court, and could not be used in the prosecution.