the exclusionary rule, in the case of Weeks v. United States, under the Fourth Amendment prohibiting unreasonable searches and seizures. This decision, however, created the rule only on the federal level. The "Weeks rule," which made an exception for cases at the state level, was adopted by numerous states at a time during prohibition. In adopting the rule, actions by states often reflected attitudes towards prohibition, which was enacted by adoption of the Eighteenth Amendment and was enforced through the Volstead Act. Concerns about privacy violations also extended to other instances where criminal sanctions were permitted for "victimless" crime, such as illegal gambling or narcotics violations. In 1920, the U.S. Supreme Court adopted the "fruit of the poisonous tree" doctrine in the case of Silverthorne Lumber Co. v. United States. The Court stated that allowing evidence gathered as an indirect result of an unconstitutional search and seizure "reduces the Fourth Amendment to a form of words". Wolf v. Colorado ruled that states were not required to adopt the exclusionary rule. Despite the ruling, some states adopted the exclusionary rule. In 1955, the Supreme Court of California ruled in People v. Cahan that the exclusionary rule applied for cases in the state of California. By 1960, 22 states had adopted the rule without substantial qualifications: California, Delaware, Florida, Idaho, Illinois, Indiana, Kentucky, Mississippi, Missouri, Montana, North Carolina, Oklahoma, Oregon, Rhode Island, Tennessee, Washington, Texas, West Virginia, Wisconsin, Wyoming. Michigan also had an exclusionary rule, but with limitations for some narcotics and firearms evidence. In Alabama, Maryland, and South Dakota, the exclusionary rule applied in some situations. It was not until Mapp v. Ohio in 1961 that the exclusionary rule was also held to be binding on the states through the Fourteenth Amendment, which guarantees due process. Up until Mapp, the exclusionary rule had been rejected by most states. In 2016, Utah v. Strieff dealt with the exclusionary rule and outstanding warrants and was viewed to be generally favorable towards police. Scope and limitations of the rule Scope The exclusionary rule does not apply in a civil case, in a grand jury proceeding, or in a parole revocation hearing. The law in force at the time of the police action, not the time of the attempt to introduce the evidence, controls whether the action is illegal for exclusionary rule purposes. Evidence obtained indirectly from illegal activity Under the “fruit of the poisonous