The Fourth Amendment applies to governmental searches and seizures, but not those done by private citizens or organizations who are not acting on behalf of a government.[16] The Bill of Rights originally only restricted the federal government. However, in Mapp v. Ohio, 367 U.S. 643 (1961), the Supreme Court ruled that the Fourth Amendment applies to the states by way of the Due Process Clause of the Fourteenth Amendment. Moreover, all state constitutions contain an analogous provision.[17]
Federal jurisdiction regarding criminal law was narrow, until the late 19th century when the Interstate Commerce Act and Sherman Antitrust Act were passed. As federal criminal jurisdiction expanded to include other areas, such asnarcotics, more questions about the Fourth Amendment came to the Supreme Court.[18]
The Supreme Court ruled that some searches and seizures may violate the