The Mapp decision is a landmark case in the development of search and seizure law. Dollree Mapp lived in Cleveland, Ohio, where police forcibly entered her house without a search warrant and found obscene items. After being prosecuted and convicted, Mapp appealed her conviction to the Supreme Court. While the Court had long held that the Fourth Amendment of the U.S. Constitution prohibits "unreasonable searches and seizures" by law enforcement officers, it had limited the application of this constitutional protection to the actions of federal officers. In Mapp, the Court expanded the reach of the Fourth Amendment to the actions of state law enforcement officers. Evidence illegally obtained could be excluded from trial. After Mapp, the use of search warrants increased dramatically in all states.