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]
| 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. | |
Case
editThe 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]
Decision
editOn 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]
Aftermath
editIn 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]
See also
editReferences
edit- ^ Gilbert G. Garcia; Hunter J. White (February 12, 2018). "Anniversary of Chambers v. Florida: Confessions through Duress must be Suppressed". The Gilbert G. Garcia Law Firm. Archived from the original on July 20, 2020. Retrieved July 20, 2020.
- ^ Klarman, Michael J. (July 31, 2007). Brown v. Board of Education and the Civil Rights Movement. Abridged Edition of "From Jim Crow to Civil Rights: The Supreme Court and the Struggle for Racial Equality" --> Chapter 3: Brown v. Board of Education. New York. ISBN 978-0-19-530763-4. Archived from the original on July 20, 2020. Retrieved July 20, 2020.
{{cite book}}: CS1 maint: location missing publisher (link) - ^ Chambers v. Florida, 309 U.S. 227 (1940).
- ^ https://www.law.umich.edu/special/exoneration/Pages/casedetailpre1989.aspx?caseid=423#:~:text=On%20the%20night%20of%20May,interrogated%20them%20about%20the%20murder.
- ^ Chambers v. State, 136 Fla. 568, 187 So. 156 (1939).
- ^ "Thurgood Marshall Biography (1908–1993)". The Biography.com website. A&E Television Networks. January 11, 2021. Archived from the original on January 20, 2021. Retrieved January 22, 2021.
- ^ See appearances of counsel listing in Miranda decision.
- ^ Williamson v. Baker, 148 Fla. 387, 388-389, 4 So. 2d 471, 471-472 (1941) (discussing the Chambers case).
External links
edit
Works related to Chambers v. Florida at Wikisource- Text of Chambers v. Florida, 309 U.S. 227 (1940) is available from: Cornell CourtListener Google Scholar Justia Library of Congress
