Caseflicks

Supreme Court of the United States • 1965

Linkletter v. Walker

381 U.S. 618 | 85 S. Ct. 1731 | 14 L. Ed. 2d 601 | 1965 U.S. LEXIS 2283 | 5 Ohio Misc. 49 | 33 Ohio Op. 2d 118

Full access

Unlock the video and quiz

The written brief is free to read below. Subscribe to watch the video explainer and take the quiz.

Create an account Log in

Takeaway

In short, Linkletter established that Mapp's state exclusionary rule applied to pending cases but not to convictions already final when Mapp was decided, using a purpose, reliance, and administrative-impact approach to retroactivity.

Background

Euel Linkletter was convicted of simple burglary in Louisiana in 1959. After his arrest, police searched him, took his keys, and later used the keys to enter and search his home and business without warrants. They seized property and papers that were used against him at trial. The Louisiana courts upheld the conviction, and it became final in 1960.

In 1961, the Supreme Court decided Mapp v. Ohio, requiring state courts to exclude evidence obtained through unconstitutional searches and seizures. Linkletter promptly sought state and federal habeas relief under Mapp. The Fifth Circuit concluded that the searches were illegal because they were too remote from the arrest, but it denied relief because Mapp did not apply to convictions that had become final before Mapp was decided. The Supreme Court granted review to resolve the conflict over Mapp's retroactive effect.

Issues

Issue #1

Whether the exclusionary rule announced in Mapp v. Ohio applies on collateral review to state convictions that became final before Mapp was decided.

Holding

No. Mapp does not apply retroactively to state convictions that were final before June 19, 1961.

Reasoning

The Court rejected the premise that every new constitutional decision must either apply fully retroactively or only prospectively. A new rule ordinarily governs the case announcing it and cases still pending on direct review, but its application to already-final judgments may depend on the circumstances. The Constitution neither compels nor forbids retroactivity in this setting.

The Court drew on decisions such as Chicot County Drainage District v. Baxter State Bank and Great Northern Railway v. Sunburst Oil, which recognized that an overruled rule may remain an important operative fact for past conduct and final judgments. Retroactivity therefore calls for a practical assessment of the rule's history, purpose, reliance interests, and effect on the administration of justice.

Mapp's principal purpose was deterrence: excluding unlawfully seized evidence was meant to remove incentives for police to disregard the Fourth Amendment. Applying Mapp to completed cases would not deter searches that had already occurred, restore invaded privacy, or otherwise advance that forward-looking purpose.

States had substantially relied on Wolf v. Colorado, which held that the Fourth Amendment applied to the States but did not require state courts to use the federal exclusionary rule. Before Mapp, the Court had repeatedly declined to overrule Wolf, and state courts had entered final convictions in conformity with its then-governing rule.

Full retroactivity would also seriously burden the administration of justice. Courts would have to reconstruct old suppression issues despite lost evidence, unavailable witnesses, and faded memories; and convictions could be disturbed even though the evidence was reliable and the trial's factfinding process was not challenged.

The Court distinguished rules applied retroactively in cases involving coerced confessions, denial of counsel, or barriers to appellate review. Those rules protect the fairness and reliability of the adjudicatory process itself. The Mapp rule instead governs the admissibility of concededly reliable evidence and operates chiefly as a deterrent to official misconduct.

Issue #2

Whether Mapp should apply because the search of Linkletter's property occurred after the search at issue in Mapp, even though Linkletter's conviction became final before Mapp was decided.

Holding

No. The legally relevant date is the date Mapp was decided, not the date of the search in Mapp or the relative timing of the underlying searches.

Reasoning

The Court held that the Mapp rule became governing law when the Court announced its judgment on June 19, 1961. The fact that Linkletter's search occurred after the search of Dollree Mapp did not give him a claim under a constitutional exclusionary rule that had not yet been imposed on the States.

Because Linkletter's conviction, available appeals, and time for seeking certiorari had all expired before Mapp, his case was final under the Court's definition. He therefore fell outside the class of cases pending on direct review to which Mapp did apply.

Dissents

Justice Black

Reasoning

Justice Black, joined by Justice Douglas, argued that Linkletter was imprisoned on a conviction obtained with evidence the Court conceded had been unconstitutionally seized. In his view, Mapp promised that evidence obtained in violation of the Fourth Amendment could not support a state conviction, and the Court had no sound basis for withholding that protection merely because Linkletter's appeal concluded before Mapp was announced.

He criticized the finality cutoff as arbitrary. Linkletter's and Mapp's offenses occurred before Mapp, yet Mapp received relief because her case moved more slowly through the courts. Whether a defendant receives constitutional protection should not turn on the pace of a state court docket rather than on the constitutional character of the evidence used to convict him.

Justice Black accepted that courts may sometimes limit a new decision to prospective operation, particularly where retroactivity would unfairly penalize persons who reasonably relied on prior law. But Louisiana had no legitimate vested interest in keeping a person imprisoned under a conviction obtained through unconstitutional official conduct.

He rejected the majority's distinction between coerced-confession cases and search-and-seizure cases. Mapp itself treated exclusion of unlawfully seized evidence as an essential constitutional safeguard, closely connected to the Fifth Amendment protection against compelled self-incrimination. The Court should not demote that protection to a lesser status because the evidence may be reliable.

Finally, he disputed the claim that administrative difficulty justified denial of habeas relief. Similar burdens exist when courts revisit old convictions involving coerced confessions or other constitutional violations, yet habeas corpus exists to release persons held under unconstitutional convictions. The possibility that guilty defendants may receive new trials cannot justify enforcing constitutional protections only for defendants fortunate enough to have cases pending when a new decision issues.