Wolf v. Colorado case brief
338 U.S. 25 (1949).
Facts of the Case
The Colorado Supreme Court upheld a number of convictions in which evidence was admitted that would have been inadmissible in a prosecution for violation of a federal law in a federal court.
Were the states required to exclude illegally seized evidence from trial under the Fourth and Fourteenth Amendments?
In a 6-to-3 decision, the Court held that the Fourteenth Amendment did not subject criminal justice in the states to specific limitations and that illegally obtained evidence did not have to be excluded from trials in all cases. The Court reasoned that while the exclusion of evidence may have been an effective way to deter unreasonable searches, other methods could be equally effective and would not fall below the minimal standards assured by the Due Process Clause. Civil remedies, such as "the internal discipline of the police, under the eyes of an alert public opinion," were sufficient.
Non-textual and Weeks rule not announced until 1914.
Many states do not have an exclusionary rule.
In a prosecution in a state court for a state crime, the 14th Amendment does not forbid the admission of evidence obtained by an unreasonable search and seizure.