Mapp v. Ohio
Citation: 367 U.S. 643 (1961)
Facts
Cleveland police forcibly entered Dollree Mapp’s home without a warrant while searching for a bombing suspect and gambling paraphernalia. They found neither, but discovered obscene materials for which Mapp was convicted under Ohio law. The Supreme Court had previously held in Wolf v. Colorado that the Fourth Amendment applies to states but that the exclusionary rule did not.
Issue
Whether evidence obtained through a search that violates the Fourth Amendment must be excluded from state criminal proceedings.
Holding
The Supreme Court overruled Wolf and held that the exclusionary rule is constitutionally required and applies to state courts through the Fourteenth Amendment. Evidence seized in violation of the Fourth Amendment must be suppressed.
Rule
Evidence obtained in violation of the Fourth Amendment is inadmissible in criminal prosecutions in both federal and state courts. The exclusionary rule is a constitutional remedy for Fourth Amendment violations, not merely a court-made rule of evidence.
Significance
Mapp is the landmark incorporation case for the exclusionary rule and remains one of the most significant criminal procedure decisions in American history. Together with Weeks v. United States, it established the architecture of Fourth Amendment remedies. It is the foundation for study of suppression motions, standing doctrine, and the exceptions to the exclusionary rule.