Stone River Law – Criminal Defense Team

Mapp v. Ohio – Exclusionary Rule in State Prosecutions

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Prior to Mapp v. Ohio, 367 U.S. 643 (1961), the Supreme Court’s exclusionary rule was required only in federal criminal prosecutions. This case extended the applicability of the exclusionary rule to include prosecutions in state courts.

Excluding Relevant Evidence at Trial

The exclusionary rule helps prevent evidence obtained through acts that violate one’s constitutional rights from being used in court. This doctrine stems directly from the Fourth Amendment of the US Constitution, which provides protections against unreasonable searches and seizures. This includes actions such as searching homes without a warrant or a pat-down without reasonable suspicion. The exclusionary rule helps discourage police officers against conducting illegal searches and seizures, and protects defendants in court against evidence obtained through these methods.

Mapp v. Ohio – Enforcing the Fourth Amendment

Prior to the 1960s, the Exclusionary Rule was only applicable at the federal court level. This means that in state prosecutions, Law Enforcement were more likely to get away with obtaining evidence illegally. The interpretation of the Exclusionary Rule was significantly expanded by Supreme Court Decision Mapp v. Ohio in 1961. In this decision, the Supreme Court held that through the Due Process Clause of the Fourteenth Amendment, protections against evidence from unreasonable searches and seizures should include state-level cases. Therefore, all levels of law enforcement from local to federal must follow the same regulations when gathering evidence for a case.

Exceptions to the Exclusionary Rule

Although the Exclusionary Rule lays a solid groundwork for protections against illegal searches and seizures, there are a few exceptions to the rule that can be raised in court:

The good faith exception allows evidence obtained through unconstitutional acts by police to be admissible in court, as long as the law enforcement officer reasonably believed they were acting lawfully. This would be determined by the court on a case-by-case basis.

Another possible exception is the inevitable discovery doctrine. If prosecution can demonstrate the illegally obtained evidence would have been able to be discovered later through legal means, the court may allow the evidence to be considered. This is mostly due to the fact that excluding it would not serve the purpose of discouraging police misconduct, since the officers were already on a path that would have led them to the same conclusions.

Why does this matter?

The exclusionary rule plays a key role in protecting the constitutional rights of criminal defendants. When representing a client, defense attorneys should always carefully review how law enforcement obtained evidence used in their case.

If police conduct seems questionable, defense can file a motion to suppress the evidence. This can greatly affect the outcome of a case. Occasionally, the excluded evidence may make up the majority of the Prosecution’s case. Without it, the prosecution may have difficulty proving the alleged criminal behavior beyond a reasonable doubt, leading to a potentially more favorable outcome for the defendant.