The death of Dollree Mapp, reported this morning in a lovely obituary in the New York Times, caught me unawares. She was an ex-con who had once been engaged to marry the light heavyweight champion Archie Moore. She’d gone to the big house on a narcotics conviction, though she’d been living quietly in recent decades. Although I never met her personally, I’ve been living with her — figuratively speaking — for several years, thinking about her often and looking at her picture. This is because I’ve been working on her portrait.

To me Dollree Mapp was a kind of hero — one of a line of Americans who, out of idealism or desperation or both, got their backs up and sought to assert their rights under the Constitution. They are the litigants in our landmark Supreme Court cases. There are scores of them in American history, and I’ve long had a theory that their portraits ought to be hanging in our courthouses, along with the paintings of the great judges. I once wrote about this in the pages of the Sun under the headline “Framed in Court.”

The events that landed Dollree Mapp in this pantheon began on May 23, 1957, when three policemen arrived at her house in Cleveland and, according to the account in the Times, “demanded to enter.” They were searching for a man whom they wanted to question about a bombing. Mapp refused to admit them, absent a warrant. The Times calls it “a small gesture of defiance that led to a landmark United States Supreme Court ruling on the limits of police power.” The cops went away, only to return with reinforcements.

“When Miss Mapp did not come to the door immediately,” the Supeme Court would later write, “at least one of the several doors to the house was forcibly opened . . . Meanwhile Miss Mapp’s attorney arrived, but the officers, having secured their own entry, and continuing in their defiance of the law, would permit him neither to see Miss Mapp nor to enter the house. It appears that Miss Mapp was halfway down the stairs from the upper floor to the front door when the officers, in this highhanded manner, broke into the hall.”

Dollree Map “demanded to see the search warrant,” the Supreme Court wrote. “A paper, claimed to be a warrant, was held up by one of the officers. She grabbed the ‘warrant’ and placed it in her bosom. A struggle ensued in which the officers recovered the piece of paper and as a result of which they handcuffed appellant because she had been ‘belligerent.’” The police then searched the whole house, and famously failed to find the man they were searching for.

They did, however, find what the Times describes as “sexually explicit materials — books and drawings that Ms. Mapp said had belonged to a previous boarder.” So they arrested her and sent her to prison on obscenity charges. Her conviction was at first upheld on appeal, but when it got to the Supreme Court over obscenity and First Amendment questions, it took a dramatic turn. The judges instead focused on the Fourth Amendment, the one that protects against unreasonable searches and seizures.

It is something to think about the actual language of the mighty Fourth: “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” The warrants not only must issue on probable cause but they must name the persons or things to be seized.

So Mapp faced down the entire federal bench until the Nine threw out her conviction on a vote of six to three. The case established that evidence obtained by searches and seizures in violation of the Constitution is inadmissible in a criminal trial in a state court. That is what we call the exclusionary rule, and in the view of a lot of us conservatives, it is the source of a great deal of mischief. The Supreme Court has made some adjustments. But no one has been able to get entirely past the precedent known as Mapp v. Ohio.

So it seems that one woman’s belligerence is another’s bravery, and the question of what Dollree Mapp was really like is something about which I’ve often wondered as — with paint brush in one hand and a mahlstick in the other — I’ve squinted at her photo. How to catch that slight smile? How to catch that ineffable American conviction that the individual is not subservient to the state but possesses rights that are inalienable? Someday, I hope, someone better with a brush than I am will finally capture Dollree Mapp in a way that will earn her own place of honor on the courthouse wall.