Mapp v. Ohio · ¶65

The only remaining remedy, if exclusion of the evidence is not required, is an action of trespass by the homeowner against the offending officer. Mr. Justice Murphy showed how onerous and difficult it would be for the citizen to maintain that action and how meagre the relief even if the citizen prevails. 338 U. S. 42-44. The truth is that trespass actions against officers who make unlawful searches and seizures are mainly illusory remedies.

U. S. Reports, bound volume
U. S. Reports, volume 367, at 643 (Library of Congress) · transcription: Caselaw Access Project
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