Law Commons^™

More than thirty years have passed since the United States Supreme Court made these observations in the landmark case of Mapp v. Ohio." The Court, no doubt, thought it was putting an end to the wrenching problems that developed since it laid the groundwork for the exclusionary rule in Boyd v. United States in 1886. Although the merits of the exclusionary rule have been debated for many years and will be debated for years to come, the advent of the exclusionary rule raised important issues of federalism that were not resolved easily.

Introduction: The conditions in America's correctional facilities have long been cause for concern. Even those who do not advocate a comfortable quality of life for inmates recognize that basic problems such as overcrowding, inmate violence,' inadequate staffing,2 and increasing costs of building and maintaining prisons have approached crisis levels. Meanwhile, the prison population continues to swell. According to the Bureau of Justice Statistics of the United States Department of Justice, the number of prisoners incarcerated at state and federal prisons annually has grown at a rate of 8.4% in recent years.'