"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.