Mapp v. Ohio

Portrait of former Chief Justice of the United States Supreme Court, Earl Warren (1891 - 1974) wearing a glasses and smiling, circa 1960s.
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Mapp v. Ohio, 367 U.S. 643, was a key Supreme Court case in the field of criminal procedure. The Court decided that evidence that was illegally obtained would not be admissible in court. 


Decided June 19, 1961

Facts of Mapp v. Ohio:

On May 23, 1957, Cleveland police wanted to search the home of Dollree Mapp who they believed might be harboring a bombing suspect along with possibly having some illegal betting equipment.

When they first came to her door, Mapp did not allow the police entrance stating that they did not have a warrant. A few hours later, the police returned and forced their way into the house. They claimed to have a valid search warrant but did not allow Mapp to inspect it. When she grabbed the warrant anyway, they handcuffed her. While they did not find the suspect or the equipment, they did find a trunk containing pornographic materials which violated Ohio law at the time. At the original trial, the court found Mapp guilty and sentenced her to jail despite no evidence of a legal search warrant being presented. Mapp appealed to the Ohio Supreme Court and lost. She then took her case to the U.S. Supreme Court and appealed on the basis of a violation to her First Amendment right to the freedom of expression.

Supreme Court Decision:

The Supreme Court under Chief Justice Earl Warren ended up siding with Mapp with a 6-3 vote.

However, they chose to ignore the question of whether a law against the possession of obscene material violated her right to freedom of expression as explained in the First Amendment. Instead, they focused on the Fourth Amendment to the Constitution. In 1914, the Supreme Court had ruled in Weeks v. United States that illegally obtained evidence could not be used in federal courts.

However, the question remained if this would be extended to state courts. The question was whether Ohio law failed to provide Mapp her 4th Amendment protection against "unreasonable searches and seizures." The Court decided that "...all evidence obtained by searches and seizures in violation of the Constitution is, by [the Fourth Amendment], inadmissible in a state court."

Significance of Mapp v. Ohio:

The Supreme Court decision in Mapp v. Ohio was quite controversial. The requirement for ensuring that evidence was legally-obtained was placed on the court. This decision would open up the court to a number of difficult cases concerning how to apply the exclusionary rule. Two major Supreme Court decisions have made exceptions to the rule created in Mapp. In 1984, the Supreme Court under Chief Justice Warren E. Burger created the 'inevitable discovery rule' in Nix v. Williams. This rule states that if there is a piece of evidence that would have eventually been discovered through legal means, then it is admissible in a court of law.

In 1984, the Burger Court created the "good faith" exception in U.S. v. Leon. This exception allows evidence to be allowed if a police officer believes that his or her search is, in fact, legal.

Thus, the court needs to decide if they acted on 'good faith'. The court has decided this for instances where there were issues with the search warrant of which the officer was not aware.

Interesting Facts:

  • Previous to this court case, Mapp had sued boxing champion Archie Moore for breach of promise for not marrying her.
  • Don King, the future fight promoter for such boxing stars as Muhammad Ali, Larry Holmes, George Foreman, and Mike Tyson, was the target of the bombing and gave the police the name Virgil Ogletree as the possible bomber that led the police to Dollree Mapp's home where they believed he was hiding.
  • In 1970, Mapp was convicted of having $250,000 worth of stolen goods and drugs. She was sent to prison until 1981.