Fourteenth Amendment Due Process Protections
1. Mapp v. Ohio (1961)
Facts:
Police searched Dollree Mapp’s home without a valid warrant and found obscene materials. She was convicted based on this evidence.
Legal Issue:
Does the exclusionary rule, which prevents illegally obtained evidence from being used in federal courts, apply to state courts under the Fourteenth Amendment?
Decision:
Yes. The Supreme Court held that evidence obtained in violation of the Fourth Amendment is inadmissible in state courts due to the Fourteenth Amendment’s Due Process Clause.
Significance:
Incorporated the exclusionary rule to the states.
Strengthened procedural due process by protecting against unlawful searches and seizures.
2. Gideon v. Wainwright (1963)
Facts:
Clarence Gideon was denied a court-appointed attorney because Florida law only provided counsel in capital cases. He represented himself and was convicted.
Legal Issue:
Does the Fourteenth Amendment require states to provide counsel in criminal cases to defendants who cannot afford one?
Decision:
Yes. The Court ruled that the right to counsel is fundamental, and states must provide attorneys under the Due Process Clause.
Significance:
Expanded procedural due process.
Ensured fair trials by guaranteeing legal representation.
3. Loving v. Virginia (1967)
Facts:
Richard and Mildred Loving, an interracial couple, were convicted under Virginia’s anti-miscegenation law forbidding interracial marriage.
Legal Issue:
Does the Due Process Clause prohibit states from banning interracial marriage?
Decision:
Yes. The Court struck down the law, holding it violated both the Equal Protection Clause and the Due Process Clause by infringing on the fundamental right to marry.
Significance:
Applied substantive due process to protect fundamental rights.
Affirmed marriage as a liberty protected from arbitrary state interference.
4. Mathews v. Eldridge (1976)
Facts:
Eldridge was denied Social Security disability benefits without a prior hearing.
Legal Issue:
What procedural safeguards are required under the Due Process Clause before terminating government benefits?
Decision:
The Court established a balancing test weighing:
The private interest affected,
The risk of erroneous deprivation without additional procedures,
The government’s interest and administrative burden.
Significance:
Defined the flexible nature of procedural due process.
Emphasized context-specific procedural protections.
5. Obergefell v. Hodges (2015)
Facts:
Several same-sex couples challenged state bans on same-sex marriage.
Legal Issue:
Does the Fourteenth Amendment require states to license and recognize same-sex marriages?
Decision:
Yes. The Court ruled that the fundamental right to marry extends to same-sex couples under the Due Process and Equal Protection Clauses.
Significance:
Reinforced substantive due process protecting personal liberty.
Marked a historic expansion of marriage equality rights.
Summary Table
| Case | Issue | Due Process Type | Outcome | Significance |
|---|---|---|---|---|
| Mapp v. Ohio (1961) | Use of illegally obtained evidence | Procedural | Incorporated exclusionary rule to states | Strengthened search/seizure protections |
| Gideon v. Wainwright (1963) | Right to counsel in criminal cases | Procedural | States must provide counsel | Ensured fair trial rights |
| Loving v. Virginia (1967) | Ban on interracial marriage | Substantive | Struck down anti-miscegenation laws | Protected marriage as fundamental liberty |
| Mathews v. Eldridge (1976) | Procedure for terminating benefits | Procedural | Established due process balancing test | Context-specific procedural safeguards |
| Obergefell v. Hodges (2015) | Right to same-sex marriage | Substantive | Legalized same-sex marriage nationwide | Expanded marriage rights & liberty |
Key Concepts to Remember:
Procedural Due Process: Focuses on how the government acts — requiring fair procedures before depriving rights (e.g., hearings, notice).
Substantive Due Process: Protects what the government can do — limits on laws affecting fundamental rights like marriage, privacy, and bodily integrity.
The Fourteenth Amendment “incorporates” many Bill of Rights protections, applying them to the states.
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