Mapp v. Ohio and Miranda v. Arizona: An analysis

The case of Mapp vs. Ohio [367 U.S. 643 (1961)] was brought to the Supreme Court on account of Mapp’sconviction due to a transgression of an Ohio statute. Mapp was said to have violated the statue for possessing and keeping in her house various materials which are obscene in nature. The obscene materials were found in her house after a search conducted by police officers in her house. Mapp appealed her conviction before the Supreme Court, arguing that the search conducted by the police should be struck down as invalid as the same was conducted without the benefit of a warrant.

In Miranda vs. Arizona [384 U.S. 436 (1966)], Miranda was convicted of rape and kidnapping. His conviction was decided by the lower court on account of his confession before police officers. He confessed to having committed the offense when he was investigated upon after being arrested by the police. Miranda appealed his conviction before the Supreme Court, contending that the confession cannot be considered as proper basis for his conviction due to the fact that he was without the assistance of counsel during the interrogation in which the confession was made by him.

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In Mapp vs. Ohio, the Supreme Court set aside the conviction, holding that the search could not validly produce the conviction for the same was conducted without a warrant being issued for the same. The Court, citing Weeks vs. United States [232 U.S. 383 (1914)], supported its decision by saying, "conviction by means of unlawful seizures and enforced confessions should find no sanction in the judgments of the courts”. In the opinion of the Court, to convict a person based on an invalid search is a denial of the Constitutional rights of the citizens, and hence cannot be permitted by the Courts.

The conviction in Miranda vs. Arizona was likewise held invalid by the Supreme Court. In this case, the Court relied on the coercive nature of interrogations conducted by police for saying that one conducted without the presence of counsel to assist the accused is a denial of the constitutional rights of the latter. Hence, any confession made under any un-counseled interrogation cannot be sanctioned as valid evidence against the accused.

The Court, in its decision, made clear that “the person in custody must, prior to interrogation, be clearly informed that he has the right to remain silent, and that anything he says will be used against him in court; he must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation, and that, if he is indigent, a lawyer will be appointed to represent him”.

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It is believed that the decisions rendered in both cases do not handcuff the police so as to restrict them from performing their duties. In fact, it is advanced that the decisions in Mapp and Arizona even seeks to limit, if not to eradicate, the abuse sometimes perpetrated by the police in the course of arrests or investigations. It cannot be said that the doctrines laid down by the courts handcuffs the police for law and jurisprudence provides for valid exceptions to the applications of the doctrines. At most, the decisions only seek to prevent the police from having unbridled discretion in gathering evidence against suspected violators and in obtaining confessions through violation and coercion.

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After an analysis of the case, it becomes apparent that the abuses perpetrated by police officers in the conduct of their duties are the same reasons why the Court has rendered a decision which effectively limits the discretion of the police in conducting interrogations and gathering evidence against suspected violators of the law. In the same way, the cases also gave hope that after the rendition of the cases, the police would no longer be abusive for purposes of prosecuting an offender; that convictions will only be produced by evidence obtained through legally permissible means.

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References Cited:

• Mapp v. Ohio. 367 U.S. 643 (1961)
• Miranda v. Arizona. 384 U.S. 436 (1966)
• Weeks v. United States. 232 U.S. 383 (1914)

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