Course: Introduction / Law
Wolf v. Colorado (1949) is a SCOTUS decision in which the Court held that the exclusionary rule was not constitutionally required in state courts; effectively overruled by Mapp v. Ohio.
Wolf v. Colorado (1949) was a landmark United States Supreme Court case that dealt with the exclusionary rule and the Fourth Amendment. The case arose when Julius Wolf was convicted in Colorado of conspiracy to perform abortions. Wolf’s attorneys argued that evidence used against him was obtained through an unconstitutional search and seizure and should therefore be excluded from his trial.
The Court’s decision in Wolf v. Colorado was significant because it held that the Fourth Amendment’s prohibition on unreasonable searches and seizures did not apply to state criminal trials. At the time, the exclusionary rule – which holds that evidence obtained through an unconstitutional search or seizure cannot be used in a criminal trial – was a relatively new legal concept. The Court had only recently applied the rule to federal criminal trials in the landmark case of Weeks v. United States (1914).
The majority opinion in Wolf v. Colorado, written by Justice Frankfurter, acknowledged that the Fourth Amendment was “one of the great landmarks in man’s struggle to make himself free from arbitrary power.” However, Frankfurter argued that the amendment’s protections should not be extended to state criminal trials through the incorporation doctrine. The incorporation doctrine holds that certain protections in the Bill of Rights apply to state criminal trials through the Fourteenth Amendment’s due process clause.
Frankfurter’s opinion was based on the idea that the states should be allowed to experiment with different approaches to criminal justice and that the exclusionary rule might not be necessary or effective in all states. He also argued that state courts could provide adequate protection against unconstitutional searches and seizures without the need for the exclusionary rule.
Justice Black, in a dissenting opinion, argued that the Fourth Amendment’s protections against unreasonable searches and seizures should apply to state criminal trials through the incorporation doctrine. Black’s argument was based on the idea that the Bill of Rights was intended to apply to all levels of government, not just the federal government. He also argued that the exclusionary rule was necessary to deter police from engaging in unconstitutional searches and seizures.
The Wolf decision remained in effect until it was overruled by the landmark case of Mapp v. Ohio in 1961. In Mapp, the Court held that the exclusionary rule applied to state criminal trials through the incorporation doctrine. Mapp was a significant step in the Court’s ongoing effort to apply the protections of the Bill of Rights to state criminal trials and to ensure that defendants receive a fair trial.
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Last Modified: 04/08/2023