Mapp v. Ohio

Studying the Mapp v. Ohio case, or interested in learning more? We break down the summary, brief, key players, facts and outcomes for you on TestMax.

Mapp v. Ohio Summary

The Supreme Court ruled in favor of Mapp, whose home was searched without a warrant by the Cleveland police and whose property was seized during that search. The Court held that the “search and seizure” that took place was unconstitutional as a violation of the Fourth Amendment “right to privacy” and the Due Process Clause of the Fourteenth Amendment. The Court’s decision upheld application of the exclusionary rule, which excludes from admissibility as trial evidence any evidence that is gathered through a warrantless search and seizure process.

Key Players in Mapp v. Ohio

  • 1Appellant: Mapp, whose home was improperly searched (apparently. without a warrant) and who was subsequently convicted in Ohio on the basis of possessing “lewd and lascivious” materials, which had been seized from her home during that search.
  • 2Appellee: The state of Ohio and its police force who, without a warrant, searched Mapp’s home and seized illegal materials from it.

Mapp v. Ohio Brief

The central themes of this case are searches and seizures, the right to privacy included in the Fourth Amendment, the exclusionary rule, and the Due Process Clause of the Fourteenth Amendment.

Mapp v. Ohio Facts

The Cleveland police sought to question Miss Mapp about a bombing. The police also wanted to conduct a search based on a report of “policy paraphernalia” connected to the bombing being present in the home. The police came to the door and requested access to the home; but, after conferring with her attorney, Miss Mapp refused to let the police enter her home or question her. The police then left the residence but began to conduct surveillance on the home. Hours later, the police returned to Mapp’s house without a warrant, forced open the door, provided Mapp with a purported warrant, and searched the entire house. They police handcuffed Mapp after a struggle over the purported warrant document. The police searched the entire house, including the suspect’s room, her child’s room, and the basement of the house. In the basement of the residence, the police found illegal “lewd and lascivious” materials. The police seized the materials and arrested Mapp for possession of the same. The prosecution had no evidence of a warrant in the Ohio trial, but Map was nevertheless convicted based on the evidence seized through the search. Mapp appealed. The state had contended that, based on law from another state, evidence of a state crime gathered from an “unreasonable search and seizure” is admissible even though the search violated the Fourteenth Amendment.

The Mapp v. Ohio Decision

The outcome of this case was a ruling in favor of the appellants based on the fact that conducting a warrantless search of private property was a violation of the Fourth Amendment right to privacy as a “right to be secure against rude invasions of…[private property]…by state officers”. The Court described how the Fourth and Fifth Amendments “apply to…invasions on the part of the government…of a man’s home and the privacies of life”. It countered the state’s argument from the lower court with the note that protections for “the security of person and property” need be “liberally construed”. Adding to that counter-argument, it noted how courts have found that using evidence unconstitutionally gathered during trial denies suspects their constitutional rights.

The Court also found that inherent in that “right to be secure against” such invasions to privacy was the exclusion of evidence gathered by way of unconstitutional search and seizure procedures. It outlined how the exclusion of such evidence is required based on the holding in the Weeks case and subsequent cases. It noted that the failure of the court in the state case cited by Ohio to recognize the exclusionary rule alongside protections for the Fourth Amendment right to privacy was the result of an unusual fact pattern. The Court explained how the Due Process Clause allowed for enforcement of the Fourth Amendment right to privacy through such exclusion of evidence. It went on to state that the enforcement of the Fourth Amendment right to privacy via the Due Process Clause is permissible against states as well as against the federal government.

Key Takeaways for Law Students

  • 1A warrantless search and seizure process is a violation of the Fourth Amendment right to privacy.
  • 2Exclusion of evidence gathered through a warrantless search and seizure process under the exclusionary rule is required under the Due Process Clause. That is, the Due Process Clause allows for enforcement of the right to privacy through exclusion of evidence.