Linkletter v. Walker
381 U.S. 618 (1965)
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Rule of Law:
A new constitutional rule in a criminal procedure case will not be applied retroactively to cases that have become final before the new rule was announced. The decision of whether to apply a new rule retroactively depends on the purpose of the new rule, the reliance on the old rule, and the effect of retroactive application on the administration of justice.
Facts:
- Police in Louisiana suspected Victor Linkletter of committing a burglary.
- Officers placed Linkletter under surveillance for two days.
- Following his arrest, police took keys from Linkletter's person.
- Without a warrant, officers used the keys to enter and search Linkletter's home.
- Later, officers also entered and searched Linkletter's place of business without a warrant.
- During these searches, police seized certain property and papers that were later used as evidence against him.
Procedural Posture:
- Victor Linkletter was convicted of simple burglary in a Louisiana state trial court in 1959.
- At trial, the court admitted evidence seized from his home and business, finding the searches valid.
- The Supreme Court of Louisiana, the state's highest court, affirmed the conviction in 1960.
- After the U.S. Supreme Court decided Mapp v. Ohio in 1961, Linkletter filed a habeas corpus petition in state court, which was denied.
- Linkletter then filed a habeas corpus petition in the United States District Court, which also denied the writ.
- Linkletter (appellant) appealed to the U.S. Court of Appeals for the Fifth Circuit, which affirmed the district court's denial, holding that Mapp did not apply retroactively.
- The U.S. Supreme Court granted certiorari to resolve the issue.
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Issue:
Does the exclusionary rule established in Mapp v. Ohio, which prohibits the use of unconstitutionally seized evidence in state criminal trials, apply retroactively to invalidate state court convictions that became final before the Mapp decision was rendered?
Opinions:
Majority - Justice Clark
No, the exclusionary rule announced in Mapp v. Ohio does not operate retroactively on cases that were final before the decision. The Constitution neither prohibits nor requires that new judicial rules be applied retrospectively. The prime purpose of the Mapp rule was to deter lawless police action, a goal that is not advanced by releasing prisoners whose illegal searches occurred prior to the new rule's establishment. The states had reasonably relied on the Court's previous holding in Wolf v. Colorado, and applying Mapp retroactively would severely disrupt the administration of justice by requiring hearings on long-concluded cases where evidence may be lost and witnesses' memories have faded. Unlike rules concerning coerced confessions, which affect the fairness and reliability of the fact-finding process, the exclusionary rule for illegally seized evidence does not bear on the defendant's guilt or innocence.
Dissenting - Justice Black
Yes, the exclusionary rule from Mapp v. Ohio should apply retroactively. The majority's decision creates an arbitrary and discriminatory distinction between defendants like Miss Mapp, who is now free, and Linkletter, who remains in prison for a conviction based on the same kind of unconstitutional evidence. The purpose of the exclusionary rule is not merely to deter police but to enforce a fundamental constitutional right belonging to the accused. It is unjust for the state to have a 'vested interest' in keeping a person in jail based on a conviction that is now known to be unconstitutional, and the practical difficulties of retrials do not outweigh the imperative to remedy a constitutional violation.
Analysis:
This case is significant for establishing the Court's modern framework for analyzing the retroactivity of new constitutional rules in criminal procedure. By rejecting a universal rule of either full retroactivity or pure prospectivity, the Court created a flexible, purpose-driven balancing test. This decision limited the immediate impact of the Mapp ruling, preventing a 'wholesale release' of prisoners and preserving the finality of convictions. The Linkletter test became the foundation for subsequent decisions determining the retroactive effect of other landmark criminal procedure rulings, shaping the practical application of constitutional law for decades.
