Linkletter v. Walker

The most important question of this case was whether provisions of the exclusionary rule, as developed in Mapp v. Ohio, should be applied retroactively. The Linkletter ruling served to instruct lower courts that the decision in Mapp was authoritative only for future cases and that no previously adjudicated cases should be reconsidered.

The petitioner, Victor Linkletter, was arrested on suspicion of burglary. At the time he was arrested, the police suspected that he was involved in other "breaking and entering" crimes. In the police station, officers confiscated his keys during a search of his person. Without a warrant, police officers subsequently entered Linkletter's home and appropriated some of his personal effects. Police officers also confiscated Linkletter's personal effects during a search of his work place. These intrusions were justified according to the District Court of Louisiana; police officers had "reasonable cause for the arrest under Louisiana law" and therefore "probable cause" for search and seizure. Based on evidence seized, Victor Linkletter was found guilty of burglary by the Louisiana District Court. The decision was affirmed, nine months later, by the Supreme Court of Louisiana.

Two years later, in Mapp v. Ohio (1961), the U.S. Supreme Court held that "all evidence obtained by searches and seizures in violation of the Constitution is, by (the Fourth Amendment), inadmissible in a state court." The Mapp decision thus set a precedent which ordered that all illegally obtained evidence must be excluded during trial. Although the exclusionary rule was established in Weeks v. United States (1914), the Mapp decision extended and clarified application of the exclusionary rule in federal courts and state courts. This extension of Fourth Amendment rights met with great controversy because police officers were restrained and precluded from collecting illegal, improper evidence in prosecutions.

Victor Linkletter applied for a reconsideration of his case on the basis of the exclusionary rule that was recognized and extended to all the levels of the government by the Mapp decision. He invoked a writ of habeas corpus (a petition claiming discretionary, unlawful arrest/detention) but his claim was rejected by the Louisiana courts and the U.S. district court. Linkletter's appeal to the U.S. court of appeals yielded a finding that admitted that the search and seizure in his case was unlawful, but also reasoned that "the constitutional requirement of exclusion of the evidence under Mapp was not retrospective."

On certiorari, Linkletter's attorney presented two main arguments to the U.S. Supreme Court. He maintained the appellate court made a mistake in finding that the Mapp decision was not retrospective. Further, Linkletter was empowered by the ruling in Mapp to ask for the same approach in his case because his offense occurred more than one year later after Mapp's crime, (but because he was convicted before the Mapp decision, he maintained his case should be adjudicated in the same way.

The majority justices upheld the rulings of the lower courts. In their opinion, presented by Justice Clark, they declared that "subsequent rulings" were not directly applicable to past events. They emphasized that previous cases could not be automatically affected because of the application of a new set of legal criteria. Historically, the justices found various interpretations of the law concerning compatibility of new approaches to the law vis-a-vis prior decisions, but they warned that the "past cannot be always erased by a new judicial declaration." They pointed to a diversity of circumstances that had to be taken into account before rendering "determination of unconstitutionality." The justices for the majority reasoned that facts pertaining to any previous finding had to be contemplated before any employment of judicial standard. They pointed out all the elements involved in every particular case (police conduct, claimed depreciated and deprived rights, final character of announced decisions, consequences) that had to be reconsidered. Considering past events, the Court also found that changes in law could have efficacy only on cases in direct review. Majority opinion actually found that new extensions of the law could not be applied on prior final rulings. The majority opinion also held that although Linkletter rightly contended that there were former judgments which showed applicability of "new constitutional rules" on previously closed cases, they did not feel obliged to treat Linkletter's conviction in the same manner. There was no absolute rule which required the Court to apply changes in the Constitution to previously adjudicated cases retroactively. The justices believed "that the Constitution neither prohibits nor requires retrospective effect." Accordingly, they concluded that they must only "weigh the merits and demerits in each case by looking to the prior history of the rule in question, its purpose and effect, and whether retrospective operation will further or retard its operation." The majority justices found that this perspective did not diverge from Fourth Amendment provisions.

The Court stressed that the main purpose of extending the exclusionary rule in the Mapp ruling was to prevent violation of Fourth Amendment rights. Thus, Mapp was never intended to correct or repair previously adjudicated cases. Although erroneous findings in Wolf v. People of the State of Colorado, which rejected the exclusionary rule, resulted in a great number of unreasonable searches and seizures, the Court's new ruling issued in Mapp was not reversionary. Justice Clark summed up the Court's position simply: "reparation comes too late." He also pointed out that the purpose of more effective application of Fourth Amendment rights "will not at this late date be served by the wholesale release of the guilty victims." The Court also asserted that retroactive relitigation based on Mapp would not be appropriate because rehearings would be impractical to hold after so much time had passed and much of the evidence was probably destroyed or removed. In further explaining their ruling in Mapp, the Court reasoned that the petitioner's reliance on Fay v. Noia (1963) and Reck v. Pate (1961) was inappropriate. Although the exclusionary rule in these cases was applied retroactively, they found that the cases had no similarity because they were issues about coerced confessions. The majority pointed out that: "all that the petitioner attacks is the admissibility of evidence, the reliability and relevancy of which is not questioned, and which may well have had no effect on the outcome." Furthermore, that the date evidence was illegally seized in Mapp v. Ohio was irrelevant because legal application of the ruling became valid only from the date of judgment, not from the day of the seizure.

In contrast to the majority decision, two dissenting justices reasoned that the Mapp decision was applicable to Linkletter's case. As in Mapp, Linkletter's conviction was upheld after evidence was illegally obtained. Unreasonable search and seizure also occurred; therefore, like Mapp "all evidence obtained by searches and seizures in violation of the Constitution is, by that same authority, inadmissible in a state court." The minority justices felt that Linkletter was convicted by evidence illegally obtained; they found it unacceptable to keep him in jail simply because his case was decided before the Mapp decision was rendered. The minority opinion pointed out that Mapp's crime occurred before Linkletter was arrested and accused and if the courts of Ohio had been as expeditious in adjudicating as Louisiana courts, Linkletter would have been automatically entitled to demand relief on direct review. Dissenting justices felt the majority opinion represented a discriminating approach between two very similar cases and therefore, were promoting unequal protection under the Fourth Amendment. Further, the minority opinion maintained it would be appropriate to provide a "new trial in conformity with the Constitution" for all convicts who were imprisoned due to unconstitutionally seized evidence.

Dissenting justices found the Court's reasoning that there was no equity among the cases Fay v. Noia, Reck v. Pate and Linkletter's case to be improper. They explained that, in those cases, even more than 20 years after adjudication, the Court recognized that the litigants were unlawfully convicted because of coerced confessions used against them. Thus, evidence collected in Linkletter's case, after an apparent infringement of his Fourth Amendment rights, should also be treated in a different way. Unlike the justices for the majority, they reasoned that circumstances merited full protection under the Constitution and, consequently, a new fair trial.