The application of the Exclusionary Rule and the Fruit of the Poisonous Tree doctrine to the States arises due to the constitutional doctrine of Incorporation.
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Incorporation Doctrine
Incorporation is a constitutional doctrine that involves the extension of the protections of the Bill of Rights, originally intended to restrict federal power, to limit state power as well. This extension is achieved through the Fourteenth Amendment, which guarantees all citizens ‘due process of law’ and ‘equal protection of the laws.’ This means that certain fundamental rights, such as those guaranteed by the Fourth Amendment against unreasonable searches and seizures, are protected not only against federal government infringement but also against infringement by state and local governments.
Applying the Rules to the States
The key Supreme Court case in the application of the Exclusionary Rule to the States is Mapp v. Ohio (1961). In Mapp, the Court held that the Fourteenth Amendment prohibits state and local officers from using evidence in state courts that was obtained in violation of the Fourth Amendment. The Court’s decision fundamentally expanded the scope of the Exclusionary Rule, making it applicable in state as well as federal courts.
The Fruit of the Poisonous Tree doctrine has also been applied to the states. This principle, originating from the federal case Silverthorne Lumber Co. v. United States (1920), prohibits the use of evidence indirectly obtained from an illegal search or seizure. This rule was then further developed and articulated in the federal context in Nardone v. United States (1939). In Mapp v. Ohio (1961), the Court applied not only the Exclusionary Rule but also the Fruit of the Poisonous Tree doctrine to the states, making any evidence indirectly obtained from an illegal search or seizure inadmissible in state courts, just as it is in federal courts.
State Law Exceptions
Despite the federal constitutional rules, it’s important to understand that states may establish their own exclusionary rules that may be more expansive than the federal Exclusionary Rule. These state rules can provide greater protections for defendants by excluding more evidence from trials in state courts. However, they cannot provide fewer protections than the federal rule due to the Supremacy Clause of the U.S. Constitution, which states that federal law is the supreme law of the land.
Summary
In sum, through the process of incorporation, both the Exclusionary Rule and the Fruit of the Poisonous Tree doctrine have been extended to apply in state court proceedings, barring the use of evidence obtained in violation of the Fourth Amendment. This application, coupled with state-specific rules, provides a robust framework for protecting individuals’ constitutional rights during the criminal justice process.
Modification History File Created: 08/08/2018 Last Modified: 08/08/2018
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