Chambers v. Mississippi

Last updated
Chambers v. Mississippi
Seal of the United States Supreme Court.svg
Argued November 15, 1972
Decided February 21, 1973
Full case nameLeon Chambers v. State of Mississippi
Docket no. 71-5908
Citations410 U.S. 284 ( more )
93 S. Ct. 1038. 35 L. Ed. 2d 297
Argument Oral argument
Case history
PriorChambers v. State, 252 So. 2d 217 (Miss. 1971) (per curiam); bail granted, 405 U.S. 1205 (1972); cert. granted, 405 U.S. 987(1972).
Holding
A state may not enforce its rules of evidence in a criminal trial so as to disallow the defendant the right to present reliable exculpatory evidence and thereby deny the defendant a fair trial.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas  · William J. Brennan Jr.
Potter Stewart  · Byron White
Thurgood Marshall  · Harry Blackmun
Lewis F. Powell Jr.  · William Rehnquist
Case opinions
MajorityPowell, joined by Burger, Douglas, Brennan, Stewart, Marshall, Blackmun
ConcurrenceWhite
DissentRehnquist
Laws applied
Fourteenth Amendment to the United States Constitution

Chambers v. Mississippi, 410 U.S. 284 (1973), was a United States Supreme Court case in which the Court held that a state may not enforce its rules of evidence, such as rules excluding hearsay, in a fashion that disallows a criminal defendant from presenting reliable exculpatory evidence and thus denies the defendant a fair trial.

Contents

Background

Leon Chambers, of Woodville, Mississippi, was charged by the State of Mississippi with murdering Police Officer Aaron Liberty by shooting him. Chambers pleaded not guilty and insisted throughout the proceedings that he was not the shooter. Prior to the trial, another Woodville man, Gable McDonald, told at least three people that he, not Chambers, had shot Liberty and gave a sworn confession. However, at a preliminary hearing in the case, McDonald disavowed his confession.

At Chambers' jury trial, the defense called McDonald as a witness and put his confession into evidence. On cross-examination, the prosecution presented evidence that McDonald had withdrawn and disavowed the confession. The defense then asked for permission to examine McDonald as an adverse witness. The court denied permission, basing its ruling upon Mississippi's common-law "voucher" rule, which prohibits the party that called a witness to the stand from impeaching his own witness.

The defense then sought to present testimony from three other witnesses, all of whom would have testified that McDonald told them soon after the shooting that he and not Chambers had shot Officer Liberty. The trial judge found that this testimony would constitute inadmissible hearsay and excluded it.

The jury found Chambers guilty of murder and sentenced him to life imprisonment. The Supreme Court of Mississippi affirmed the conviction with one Justice dissenting. [1]

Chambers then asked the United States Supreme Court to review his claim that the trial court's evidentiary rulings deprived him of a fair trial, in violation of the Fourteenth Amendment to the United States Constitution. While Chambers' petition for certiorari was pending, Circuit Justice Lewis F. Powell, Jr. released Chambers on bail. [2] The Court granted certiorari. [3]

Opinion of the Court

In an opinion written by Justice Powell for an eight-Justice majority, the Court agreed that Chambers had been unconstitutionally deprived of a fair trial. The Court began its analysis by observing that "[t]he right of an accused in a criminal trial to due process is, in essence, the right to a fair opportunity to defend against the State's accusations. The rights to confront and cross-examine witnesses and to call witnesses on one's own behalf have long been recognized as essential to due process." [4]

Here, because of the trial court's ruling on the defense's adverse-witness motion, "Chambers was denied an opportunity to subject McDonald's damning repudiation and alibi to cross-examination." [5] The court observed that "[t]he right of cross examination ... is implicit in the constitutional right of confrontation, and helps assure the 'accuracy of the truth-determining process.'" [5] Chambers had a constitutional right to conduct a full examination of McDonald without being bound by McDonald's testimony or barred from seeking to impeach it.

Chambers' rights were further violated by the trial judge's refusal to permit testimony from the three other witnesses, who would have testified that McDonald made statements shortly after the crime identifying himself as the shooter. Mississippi sought to defend this exclusion as a straightforward application of the hearsay rule, under which "[o]ut-of-court statements are traditionally excluded because they lack the conventional indicia of reliability," such as being made under oath and subject to cross-examination. [6] However, the Court observed, the hearsay rule has developed many exceptions that allow the admission of hearsay statements "made under circumstances that tend to assure reliability." Here, "[t]he hearsay statements involved in this case were originally made and subsequently offered at trial under circumstances that provided considerable assurance of their reliability." [7]

The Court "conclude[d] that the exclusion of this critical evidence, coupled with the State's refusal to permit Chambers to cross-examine McDonald, denied him a trial in accord with traditional and fundamental standards of due process." [8] Accordingly, Chambers' conviction was reversed.

Concurring opinion

Justice Byron R. White authored a concurring opinion discussing whether Chambers had sufficiently raised his constitutional objections to the trial court's rulings during the trial, so as to preserve them for appellate review. White expressed some skepticism on this point. However, White acknowledged that Chambers had raised his objections at trial, albeit on non-constitutional grounds, and that he had raised his due-process claim in the Mississippi Supreme Court. Moreover, the State did not argue non-preservation in opposing Chambers' petition. Therefore, White acquiesced dubitante in the majority's conclusion that the Court had jurisdiction to reach the merits. On the merits, he agreed with the majority opinion.

Dissenting opinion

Justice William H. Rehnquist dissented. In his view, the Supreme Court lacked jurisdiction over Chambers' constitutional claims because he had not raised them at trial. Rehnquist also expressed his skepticism about what he characterized as "the Court's further constitutionalization of the intricacies of the common law of evidence."

Social background to the case

The shooting of Officer Liberty took place during a period of racial unrest in Woodville, during which African-American residents were boycotting white-owned establishments to press demands for desegregation and increased services to black neighborhoods. During the boycotts, there had been a series of confrontations between members of the Deacons for Defense and the Woodville police force. The boycotters' demands had included the hiring of African-American police officers, and these demands had been granted to the extent of hiring a small number of black officers, whose superiors restricted them to acting against other blacks; Officer Liberty was himself African-American, and defendant Chambers had been the first black police officer in Woodville before being fired when he would not accept the limitations on his duties. None of this racial background and social history is mentioned anywhere in the Supreme Court opinions in the case.

Notes

  1. ↑ Chambers v. State, 252 So. 2d 217 (Miss. 1971) (per curiam).
  2. ↑ Chambers v. Mississippi, 405 U.S. 1205 (1972) (Powell, J., Circuit Justice, in chambers) (in-chambers opinion denying State's application to revoke prior unpublished order admitting Chambers to bail).
  3. ↑ Chambers v. Mississippi, 405 U.S. 987(1972).
  4. ↑ Chambers v. Mississippi, 410 U.S. 284, 294 (1973).
  5. 1 2 Chambers, 410 U.S. at 295.
  6. ↑ Chambers, 410 U.S. at 298.
  7. ↑ Chambers, 410 U.S. at 300.
  8. ↑ Chambers, 410 U.S. at 302.

Related Research Articles

Sixth Amendment to the United States Constitution 1791 amendment enumerating rights related to criminal prosecutions

The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied most of the protections of this amendment to the states through the Due Process Clause of the Fourteenth Amendment.

Hearsay is testimony from a witness under oath who is reciting an out-of-court statement that is being offered to prove the truth of the matter asserted.

Maryland v. Craig, 497 U.S. 836 (1990), was a U.S. Supreme Court case involving the Sixth Amendment. The Court ruled that the Sixth Amendment's Confrontation Clause, which provides criminal defendants with the right to confront witnesses against them, did not bar the use of one-way closed-circuit television to present testimony by an alleged child sex abuse victim.

Crawford v. Washington, 541 U.S. 36 (2004), is a United States Supreme Court decision that reformulated the standard for determining when the admission of hearsay statements in criminal cases is permitted under the Confrontation Clause of the Sixth Amendment. The Court held that cross-examination is required to admit prior testimonial statements of witnesses who have since become unavailable.

In the United States, the exclusionary rule is a legal rule, based on constitutional law, that prevents evidence collected or analyzed in violation of the defendant's constitutional rights from being used in a court of law. This may be considered an example of a prophylactic rule formulated by the judiciary in order to protect a constitutional right. The exclusionary rule may also, in some circumstances at least, be considered to follow directly from the constitutional language, such as the Fifth Amendment's command that no person "shall be compelled in any criminal case to be a witness against himself" and that no person "shall be deprived of life, liberty or property without due process of law."

Witness impeachment, in the law of evidence of the United States, is the process of calling into question the credibility of an individual testifying in a trial. The Federal Rules of Evidence contain the rules governing impeachment in US federal courts.

The Confrontation Clause of the Sixth Amendment to the United States Constitution provides that "in all criminal prosecutions, the accused shall enjoy the right…to be confronted with the witnesses against him." Generally, the right is to have a face-to-face confrontation with witnesses who are offering testimonial evidence against the accused in the form of cross-examination during a trial. The Fourteenth Amendment makes the right to confrontation applicable to the states and not just the federal government. The right only applies to criminal prosecutions, not civil cases or other proceedings.

Hearsay evidence, in a legal forum, is testimony from a witness under oath who is reciting an out-of-court statement, content of which is being offered to prove the truth of the matter asserted. In most courts, hearsay evidence is inadmissible unless an exception to the hearsay rule applies.

The hearsay provisions of the Criminal Justice Act 2003 reformed the common law relating to the admissibility of hearsay evidence in criminal proceedings begun on or after 4 April 2005.

Davis v. Washington, 547 U.S. 813 (2006), was a case decided by the Supreme Court of the United States holding that hearsay statements made in a 911 call asking for aid were not "testimonial" in nature and thus their introduction at trial did not violate the Confrontation Clause as defined in Crawford v. Washington.

In the law of evidence, a dying declaration is testimony that would normally be barred as hearsay but may in common law nonetheless be admitted as evidence in criminal law trials because it constituted the last words of a dying person. The rationale is that someone who is dying or believes death to be imminent would have less incentive to fabricate testimony, and as such, the hearsay statement carries with it some reliability.

Richardson v. Perales, 402 U.S. 389 (1971), was a case heard by the United States Supreme Court to determine and delineate several questions concerning administrative procedure in Social Security disability cases. Among the questions considered was the propriety of using physicians' written reports generated from medical examinations of a disability claimant, and whether these could constitute "substantial evidence" supportive of finding nondisability under the Social Security Act.

Troy Davis American murderer

Troy Anthony Davis was a man convicted of and executed for the August 19, 1989 murder of police officer Mark MacPhail in Savannah, Georgia. MacPhail was working as a security guard at a Burger King restaurant when he intervened to defend a man being assaulted in a nearby parking lot. During Davis's 1991 trial, seven witnesses testified they had seen Davis shoot MacPhail, and two others testified Davis had confessed the murder to them. There were 34 witnesses who testified for the prosecution, and six others for the defense, including Davis. Although the murder weapon was not recovered, ballistic evidence presented at trial linked bullets recovered at or near the scene to those at another shooting in which Davis was also charged. He was convicted of murder and various lesser charges, including the earlier shooting, and was sentenced to death in August 1991.

Whorton v. Bockting, 549 U.S. 406 (2007), was a United States Supreme Court case about the application of the Confrontation Clause and whether Crawford v. Washington (2006) applied retroactively. Justice Samuel Alito, writing for a unanimous Court, ruled that Crawford did not apply retroactively.

Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009), is a United States Supreme Court case in which the Court held that it was a violation of the Sixth Amendment right of confrontation for a prosecutor to submit a chemical drug test report without the testimony of the person who performed the test. While the court ruled that the then-common practice of submitting these reports without testimony was unconstitutional, it also held that so called "notice-and-demand" statutes are constitutional. A state would not violate the Constitution through a "notice-and-demand" statute by both putting the defendant on notice that the prosecution would submit a chemical drug test report without the testimony of the scientist and also giving the defendant sufficient time to raise an objection.

Tome v. United States, 513 U.S. 150 (1995), was a case decided by the Supreme Court of the United States that held that under Federal Rules of Evidence Rule 801(d)(1)(B), a prior consistent statement is not hearsay only if the statement was made before the motive to fabricate arose.

Cruz v. New York, 481 U.S. 186 (1987), was an important United States Supreme Court decision which held that the Confrontation Clause barred the admission, in a joint trial, of a nontestifying codefendant's confession incriminating the defendant, even if the defendant's own confession was admitted against him.

Glasser v. United States, 315 U.S. 60 (1942), was a landmark decision of the US Supreme Court on two issues of constitutional criminal procedure. Glasser was the first Supreme Court decision to hold that the Assistance of Counsel Clause of the Sixth Amendment required the reversal of a criminal defendant's conviction if his lawyer's representation of him was limited by a conflict of interest.

Pointer v. Texas, 380 U.S. 400 (1965), was a decision by the United States Supreme Court involving the application of the right of to confront accusers in state court proceedings. The Sixth Amendment in the Bill of Rights states that, in criminal prosecutions, the defendant has a right "...to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor..." In this case, a person arrested in Texas for robbery was deprived of the ability to cross-examine a witness when the lower court allowed the introduction of a transcript of that witness's earlier testimony at a preliminary proceeding instead of compelling attendance by the witness at trial.

<i>DPP v McLoughlin</i> Irish Supreme Court case

DPP v  McLoughlin, [2009] IESC 65, was an Irish Supreme Court case, which confirmed that when objecting to the granting of bail where alleged witness intimidation is raised, the judge in the application should explicitly address the likelihood, extent, and impact of intimidation. This case specifically raised the issue of hearsay in considering potential witness intimidation and in the context of a bail decision. The decision of Denham J, goes on to state in regards to hearsay that: "The relevance and weight of such evidence is a matter to be determined by the trial judge and that a judge should be careful on the weight he or she places on such evidence". The case also had implications for bail applications because the Supreme Court found that a high case load for the High Court had implications on bail decisions.

References

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.