Chambers v. Florida | |
---|---|
Argued January 4, 1940 Decided February 12, 1940 | |
Full case name | Chambers et al. v. State of Florida |
Citations | 309 U.S. 227 ( more ) 60 S. Ct. 472; 84 L. Ed. 716; 1940 U.S. LEXIS 911 |
Case history | |
Prior | Conviction affirmed, Chambers v. State, 136 Fla. 568, 187 So. 156 (1939); cert. granted, 308 U.S. 541(1939). |
Holding | |
Confessions compelled by police through duress are inadmissible at trial. | |
Court membership | |
| |
Case opinion | |
Majority | Black, joined by Hughes, McReynolds, Stone, Roberts, Reed, Frankfurter, Douglas |
Murphy took no part in the consideration or decision of the case. |
Chambers v. Florida, 309 U.S. 227 (1940), was a landmark [1] [2] United States Supreme Court case that dealt with the extent to which police pressure resulting in a criminal defendant's confession violates the Due Process Clause. [3]
The case was argued on January 6, 1940, in front of the court by S.D. McGill, a Black civil rights attorney involved with the National Association for the Advancement of Colored People, representing four black men convicted for the murder of a white man in Florida. McGill, joined by Leon A. Ransom of the NAACP National Legal Committee, argued before the U.S. Supreme Court. Thurgood Marshall, special counsel for the NAACP, appeared on the defendants’ brief but did not participate in the courtroom arguments. [4]
The defendant Chambers, along with three other co-defendants, were four of up to forty transient black men arrested for the murder of Robert Darcy, an elderly local man, in Pompano Beach, Florida. The community was outraged by the murder, and the Broward County Sheriff's department was apparently under pressure to close the case. Chambers and the other defendants were taken to Miami for questioning, ostensibly to protect them from the mob that had formed, and then to Fort Lauderdale.
The state did not contest that the defendants were held without access to legal counsel, and were not arraigned for a week. They were subjected to questioning on a random basis, often alone in a room with up to ten police officers and other members of the community. In the legal climate before Miranda , they were not informed of their right to remain silent. After a week of questioning, and despite previous denials, the four co-defendants eventually confessed to the crime and were convicted of capital murder and sentenced to death. Their convictions were affirmed by the Supreme Court of Florida. [5]
On February 13, 1940, the court delivered its ruling. The opinion of the court was delivered by Justice Hugo Black of Alabama.
This was Marshall's first [6] of many triumphs in front of the nation's highest tribunal; the Court ruled in favor of the defendants, and overturned their convictions. The court found that on the facts admitted by the police and sheriff's officers, the confessions had clearly been compelled and were therefore inadmissible. It marked one of the first times that the court had accepted the contention that treatment short of physical violence should result in the suppression of evidence.
Several of the features of this case, such as not allowing defendants to contact anyone, holding them without formal charges or arraignment, and denying them counsel during questioning were common tactics[ where? ] in law enforcement at the time[ citation needed ] and were eventually rejected by the court in Miranda v. Arizona (1966), a case in which Marshall argued on behalf of the United States government as Solicitor General of the United States. [7]
In subsequent proceedings before the Florida courts, the indictment against the defendants was quashed on the ground that blacks had been arbitrarily and intentionally excluded from the grand jury. [8]
In the United States, the Miranda warning is a type of notification customarily given by police to criminal suspects in police custody advising them of their right to silence and, in effect, protection from self-incrimination; that is, their right to refuse to answer questions or provide information to law enforcement or other officials. Named for the U.S. Supreme Court's 1966 decision Miranda v. Arizona, these rights are often referred to as Miranda rights. The purpose of such notification is to preserve the admissibility of their statements made during custodial interrogation in later criminal proceedings. The idea came from law professor Yale Kamisar, who subsequently was dubbed "the father of Miranda."
Thoroughgood "Thurgood" Marshall was an American civil rights lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1967 until 1991. He was the Supreme Court's first African-American justice. Prior to his judicial service, he was an attorney who fought for civil rights, leading the NAACP Legal Defense and Educational Fund. Marshall was a prominent figure in the movement to end racial segregation in American public schools. He won 29 of the 32 civil rights cases he argued before the Supreme Court, culminating in the Court's landmark 1954 decision in Brown v. Board of Education, which rejected the separate but equal doctrine and held segregation in public education to be unconstitutional. President Lyndon B. Johnson appointed Marshall to the Supreme Court in 1967. A staunch liberal, he frequently dissented as the Court became increasingly conservative.
Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that law enforcement in the United States must warn a person of their constitutional rights before interrogating them, or else the person's statements cannot be used as evidence at their trial. Specifically, the Court held that under the Fifth Amendment to the U.S. Constitution, the government cannot use a person's statements made in response to an interrogation while in police custody as evidence at the person's criminal trial unless they can show that the person was informed of the right to consult with a lawyer before and during questioning, and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights but also voluntarily waived them before answering questions.
Charles Hamilton Houston was an American lawyer. He was the dean of Howard University Law School and NAACP first special counsel. A graduate of Amherst College and Harvard Law School, Houston played a significant role in dismantling Jim Crow laws, especially attacking segregation in schools and racial housing covenants. He earned the title "The Man Who Killed Jim Crow".
Ernesto Arturo Miranda was an American laborer whose criminal conviction was set aside in the landmark U.S. Supreme Court case Miranda v. Arizona, which ruled that criminal suspects must be informed of their right against self-incrimination and their right to consult with an attorney before being questioned by police. This warning is known as a Miranda warning. Miranda had been convicted of kidnapping, rape, and armed robbery charges based on his confession under police interrogation.
The NAACP Legal Defense and Educational Fund, Inc. is an American civil rights organization and law firm based in New York City.
Dickerson v. United States, 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule Miranda v. Arizona (1966).
The Trenton Six is the group name for six African-American defendants tried for murder of an elderly white shopkeeper in January 1948 in Trenton, New Jersey. The six young men were convicted in August 1948 by an all-white jury of the murder and sentenced to death.
Lisenba v. California, 314 U.S. 219 (1941), was a case in which the United States Supreme Court upheld the criminal conviction and death sentence imposed upon a man who confessed to murder after being detained for more than 24 hours, slapped and deprived of sleep and food. The petitioner argued that the confession was coerced, and that it violated his due process rights under the Fourteenth Amendment to the U.S. Constitution.
The Groveland Four were four African American teens, Ernest Thomas, Charles Greenlee, Samuel Shepherd, and Walter Irvin. In July 1949, the four were accused of raping a white woman and severely beating her husband in Lake County, Florida. The oldest, Thomas, tried to elude capture and was killed that month. The others were put on trial. Shepard and Irvin received death sentences, and Greenlee was sentenced to life in prison. The events of the case led to serious questions about the arrests, allegedly coerced confessions and mistreatment, and the unusual sentencing following their convictions. Their incarceration was exacerbated by their systemic and unlawful treatment—including the death of Shepherd, and the near-fatal shooting of Irvin. Greenlee was paroled in 1962 and Irvin in 1968. All four were posthumously exonerated by the state of Florida in 2021.
Brown v. Mississippi, 297 U.S. 278 (1936), was a United States Supreme Court case that ruled that a defendant's involuntary confession that is extracted by the use of force on the part of law enforcement cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
McNeil v. Wisconsin, 501 U.S. 171 (1991), held that the right to counsel secured by the Sixth Amendment and the right to counsel protected by Miranda v. Arizona are separate and distinct, such that invoking one does not implicitly invoke the other.
Massiah v. United States, 377 U.S. 201 (1964), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the government from eliciting statements from the defendant about themselves after the point that the Sixth Amendment right to counsel attaches.
Colorado v. Connelly, 479 U.S. 157 (1986), was a U.S. Supreme Court case that was initiated by Francis Connelly, who insisted that his schizophrenic episode rendered him incompetent, nullifying his waiver of his Miranda rights.
Michigan v. Jackson, 475 U.S. 625 (1986), was a case decided by the United States Supreme Court regarding the Sixth Amendment's right to counsel in a police interrogation. In a decision written by Justice Stevens, the Court held that once an accused individual has claimed a right to counsel at a plea hearing or other court proceeding, a waiver of that right during later police questioning would be invalid unless the accused individual initiated the communication.
Montejo v. Louisiana, 556 U.S. 778 (2009), is a 5–4 decision by the United States Supreme Court that overruled the Court's decision in Michigan v. Jackson. The case concerned the validity of a defendant's waiver of his right to counsel during a police interrogation. In reversing Jackson, the Court said such a waiver was valid.
Edwards v. Arizona, 451 U.S. 477 (1981), is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel, police must cease custodial interrogation. Re-interrogation is only permissible once defendant's counsel has been made available to him, or he himself initiates further communication, exchanges, or conversations with the police. Statements obtained in violation of this rule are a violation of a defendant's Fifth Amendment rights.
Devil in the Grove: Thurgood Marshall, the Groveland Boys, and the Dawn of a New America is a 2012 nonfiction book by the American author Gilbert King. It is a history of the attorney Thurgood Marshall's defense of four young black men in Lake County, Florida, who were accused in 1949 of raping a white woman. They were known as the Groveland Boys. Marshall led a team from the NAACP Legal Defense Fund. Published by Harper, the book was awarded the 2013 Pulitzer Prize for General Nonfiction. The Pulitzer Committee described it as "a richly detailed chronicle of racial injustice."
Lyons v. Oklahoma, 322 U.S. 596 (1944), was a United States Supreme Court case about the beatings and subsequent coerced confessions of William Douglas Lyons, a man convicted of a triple murder in Oklahoma. His attorneys included Thurgood Marshall.
Illinois v. Perkins, 496 U.S. 292 (1990), was a decision by the United States Supreme Court that held that undercover police agents did not need to give Miranda warnings when talking to suspects in jail. Miranda warnings, named after the 1966 Supreme Court case Miranda v. Arizona, are generally required when police interrogate suspects in custody in order to protect the right not to self-incriminate and the right to counsel under the Fifth and Sixth Amendments. However, the Court ruled that potential coercion must be evaluated from the suspect's point of view, and if they are unaware that they are speaking to police, they are not under the coercive pressure of a normal interrogation.
{{cite book}}
: CS1 maint: location missing publisher (link)