Linkletter v. Walker

Background

A man in Louisiana was arrested and convicted in 1959 for burglary based on property and papers taken after warrantless searches of his person, home, and business. The Louisiana courts affirmed the conviction in March 1960. In 1961 the Court decided Mapp v. Ohio, declaring that state courts must exclude evidence seized in violation of the Fourth Amendment. The prisoner then sought relief in state and federal habeas proceedings, which were denied.

Reasoning

The Court asked whether Mapp’s rule applies to convictions that were already final before Mapp. The majority reviewed history and prior cases, noted reliance on the earlier Wolf rule, and weighed Mapp’s purpose of deterring unlawful searches against practical burdens of reopening final cases. It concluded that Mapp should operate for direct or pending cases but not retroactively to final convictions, so the petitioner’s conviction stands despite the unconstitutional searches.

Real world impact

People jailed on convictions that became final before Mapp cannot use the Mapp exclusion to get new trials. The decision leaves intact many state convictions and limits relief to cases decided after or still under review at the time of Mapp. The ruling emphasizes administrative burdens and reliance interests in keeping final convictions undisturbed. It recognizes Mapp for cases on direct review and pending appeals.

Dissents or concurrances

Justice Black, joined by Justice Douglas, dissented, arguing the Court broke Mapp’s promise, that applying the rule only prospectively is arbitrary, and that prisoners now in jail because of illegally seized evidence should receive new trials.