Mapp was convicted under Ohio law for possessing "lewd, salasious, or obscene material." Mapp appealed her conviction. She based her claim on First Amendment grounds, saying that she had a right to possess the materials. When the case reached the Supreme Court, however, the Justices did not address her First Amendment claim. The Court instead overturned her conviction because the evidence against her had been seized without a warrant. ln so ruling, the Court applied the exclusionary rule to the states.