Supreme Court of the United States · 1965 · Federal Courts
Federal CourtsRetroactivityHabeas CorpusFourth Amendmentretroactivitycollateral attackfinal convictionsMapp v. Ohio
Facts
Petitioner was convicted in Louisiana in 1959 of simple burglary. After his arrest, officers took his keys, later entered and searched his home and place of business without a warrant, and seized property and papers. The Louisiana courts upheld the seizures and affirmed his conviction in 1960, before Mapp was decided. After Mapp was announced in 1961, petitioner sought habeas corpus on the ground that the evidence used against him had been illegally seized.
Issue
Does Mapp v. Ohio, which required state courts to exclude evidence seized in violation of the Fourth Amendment, apply retroactively to state convictions that became final before Mapp was decided? If not, should petitioner still get the benefit of Mapp because the search in his case occurred after the search in Mapp even though his conviction became final earlier?
Rule
A new constitutional rule need not be applied retroactively to cases already final on collateral review. Whether such a rule applies to prior final judgments depends on consideration of the rule's prior history, its purpose and effect, the extent of reliance on the old rule, and the effect of retroactive application on the administration of justice; meanwhile, changes in law are applied to cases still on direct review.
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In 1958, Omar Benton was convicted in an Ohio court after police introduced documents seized during a warrantless search of his apartment in Cleveland. His conviction was affirmed on appeal in 1959, and the time to seek further review expired that year. In 1962, he files a federal habeas petition arguing that the evidence should have been excluded under a later Supreme Court decision requiring state courts to exclude unlawfully seized evidence.
How should the federal court rule?
Explanation. The majority held that a new constitutional rule like the state-applicable exclusionary rule need not be applied retroactively to cases already final and attacked collaterally. For final convictions, retroactivity depends on factors such as the rule's purpose, reliance on the old rule, and the effect on the administration of justice. Because the conviction was final before the new rule was announced, habeas relief is unavailable.