Case brief summary
If police violate the Fourth Amendment's ban on unreasonable searches and seizures, the evidence they find cannot be used against the defendant in state court.
Facts
Cleveland police forced their way into Dollree Mapp's home without a valid warrant searching for a bombing suspect and found obscene materials, leading to her conviction.
Procedural history
Ohio's trial court convicted Mapp, and Ohio's Supreme Court upheld the conviction even though it found the search unlawful, because no violent force was used against her body.
Issue
Does the federal Constitution require state courts to exclude evidence obtained through an illegal police search, the same way federal courts must?
Holding
Yes, the Supreme Court ruled that states, just like the federal government, cannot use evidence obtained through unconstitutional searches in criminal trials.
Reasoning
The Court reasoned that a constitutional right to privacy means nothing if police can violate it and still use what they find, so the same exclusion rule used in federal courts must bind the states too.
Opinions
Majority (Clark): Held the exclusionary rule is part of the Fourth Amendment right itself and must apply to states, overruling an earlier Supreme Court decision allowing states to admit illegally seized evidence.
Concurrences (Black and Douglas): Black grounded the rule in both the search and seizure amendment and the self-incrimination amendment together, while Douglas stressed the lawless facts and defended deciding the issue now.
Dissent (Harlan): Argued the Court wrongly reached out to decide an issue not properly argued and that states should remain free to choose their own remedies for illegal searches.