Mapp v. Ohio celebrates its 60th anniversary in June 2021. The landmark Supreme Court case held that the exclusionary rule, which threw out illegally obtained evidence in a court of law, applied to both US states and the federal government. The case remains a critical ruling in America today and dictates much of how courts and law enforcement act in criminal matters, and also remains impactful for American race relations.
Law enforcement officers arrived one day in 1957 at the house of Dollree Mapp, a Black woman living in Cleveland, Ohio. The police were searching for a bombing suspect, but Mapp denied them entry into her house without a warrant. The officers produced a piece of paper that was not a warrant and entered the house anyway, handcuffing Mapp and searching through her personal belongings. The police found what was deemed to be “obscene material”, which was illegal to own in Ohio at the time, and Mapp was arrested and convicted. Mapp appealed her conviction, which was upheld by the Ohio Supreme Court. She then subsequently appealed to the US Supreme Court on the issue of obscene material. The ruling of the Supreme Court, in this case, is based on the legal fundamentals of illegal search and seizure.
The ruling of Mapp v. Ohio imposed the exclusionary rule on both state and federal courts. Essentially, this excluded all evidence that was obtained in methods that violated the Fourth Amendment from being introduced in a court of law. The impacts of this ruling in the past sixty years have been plentiful in various areas of public life. Besides the ways in which this ruling has changed American policing, Mapp v. Ohio is known as a landmark ruling when it comes to the civil rights of Black Americans. Although race was supposedly not a factor in the Warren Court’s ruling, it is clear that race played a major role in the facts and significance of the case.
The Warren Court was deeply involved in cases surrounding race and civil rights during this time period. Bolling v. Sharpe in 1954 saw the Court hold that the Fifth Amendment guaranteed racial equality in DC public education. It was also during the Warren Court period in which Congress enacted legislation that sought to address racial discrimination and segregation through the Civil Rights Act of 1964 and the Voting Rights Act of 1965. However, the Court is most well known for its groundbreaking civil rights case Brown v. Board of Education, which essentially ended segregation in public schools. Scholars point to the racial context of the Warren Court as a major factor behind the decisions of individual justices in Mapp v. Ohio. Thomas Davies argues in the Northwestern University Journal of Criminal Law and Criminology that “the confluence of racist police abuse in Mapp and Monroe may have convinced Justice [Tom] Clark that it was past time to extend federal supervision to state criminal justice.”
Lewis Katz, at the Case Western University School of Law, sums up the fundamental outcome of Mapp v. Ohio as “the government must obey the law when enforcing it.” He argues that the impacts of Mapp are most felt in areas where law enforcement has the least restraint imposed upon them. The ruling of Mapp inherently standardized the ways in which law enforcement applied their practices to all Americans, no matter their ethnicity. Katz identifies this standardization as a way to curb unfair practices law enforcement officers used against minorities that they did not use against white people in America during this time. William Plouffe in the Encyclopedia of Race and Crime notes that the importance of Mapp v. Ohio was that it created constitutional standards for all law enforcement in all scenarios, regardless of the people involved.
In theory, Mapp v. Ohio essentially offered a solution to a system where differing practices of law enforcement based on the race of those involved are well documented. It was supposed to curb the impacts police practices had on the Black community across the United States and put an end to practices such as “arbitrarily stopping and detaining African-Americans, engaging in dragnet arrests of African-Americans, and, as in the Mapp case, entering homes without warrants,” Katz articulates. However, as we enter 60 years after the ruling, it is unclear as to whether the case has made the broad steps in terms of preventing racist policing practices it was intended on.
Anders Walker in his piece “To Corral and Control” in the University of Richmond Law Review argues that the ruling of Mapp v. Ohio coincided with a severe increase in police corruption. “Not only did Mapp reduce arrests,” Walker claims, “but it also encouraged police to stretch the truth, telling more elaborate “stories” to bolster the arrests they did make.” Police officers used extremely questionable tactics such as “frisking” a suspect violently in order to cajole or force out any suspicious items and cause them to fall, therefore absolving the need for a warrant. Law enforcement officers also began to utilize the ruling in Terry v. Ohio only seven years after Mapp, which ruled that only “reasonable suspicion” was necessary for investigative stop instead of “probable cause,” to establish stoppage systems in “high crime areas,” which were predominantly minority municipalities.
Other Supreme Court cases decided in the aftermath of Mapp v. Ohio, even by the Warren Court, have limited the impact Mapp has had on both policing practices and race relations. Calandra v. United States in 1974 saw the Court hold that citizens could not seek to throw out illegally seized evidence when having to answer questions in front of a grand jury. In addition, Leon v. United States permitted deviation from the exclusionary rule if law enforcement used warrants that lacked probable cause. Refusal to suppress evidence from questionable or illegally obtained search and seizure methods continues to this day: in 2006, the Court refused to throw out evidence that was taken by police officers who had failed to knock or announce their presence when entering a private home.
These rulings weakened the original strength of Mapp v. Ohio and brought back questionable law enforcement tactics into the mainstream. It is also clear that Mapp may not have served as a deterrent to shady arrest practices but instead simply forced officers into changing their strategies in order to arrest. The New York Legal Services saw that following Mapp, locations for arrests generally shifted away from private rooms and to public spaces, meaning that officers have tried to seek other alternatives to arrests instead of attempting to attain a warrant. Policing organizations have also attempted to use political clout to scale back the limitations imposed on them by Mapp. For example, the NYPD pushed for state laws that authorized arrests in the case in which they had “reasonable grounds” or “cause” to believe that a crime had occurred.
Solutions to solve the unintended consequences of Mapp are plentiful and certainly mixed. Some legal scholars such as William T. Pizzi advocate for overturning the ruling altogether. He argues that, despite the intentions of the exclusionary rule and the relevance it had in context to the time of the decision, “the rule is based on an assumption which has proven dangerous over the years, namely, the belief that harsh mandatory punishments will deter undesirable social behaviors.” Other advocates or legislators have pushed back on certain practices by law enforcement by passing legislation banning “stop and frisk.”
60 years after the ruling, Mapp v. Ohio’s long-term impacts remain unknown. Although its lasting repercussions are still debated and its legacy mixed, it is a showcase in how Supreme Court cases have direct repercussions on the daily lives of many US citizens.