Chambers v. Florida
Encyclopedia
Chambers v. Florida, 309 U.S. 227 (1940), was an important United States Supreme Court
case that dealt with the extent that police pressure resulting in a criminal defendant's confession violates the Due Process
clause.
, representing four black men convicted for the murder of a white man in Florida
.
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 murder was greeted with outrage in the community 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.
It was not contested that the defendants were held without being able to see a lawyer or be arraigned for a period of a week, or that they were subject 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 appeals to the Florida Court of Appeals was rejected on the grounds that the jury had ruled the confessions had been given voluntarily.
of Alabama
.
This was Marshall's first 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 the defendant to contact anyone, holding them without formal charges or arraignment
, and denying them counsel during questioning were common tactics in law enforcement at the time and were eventually rejected by the court in Miranda v. Arizona
(1966).
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case that dealt with the extent that police pressure resulting in a criminal defendant's confession violates the Due Process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
clause.
Case
The case was argued on January 6, 1940 in front of the court by Thurgood MarshallThurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
, representing four black men convicted for the murder of a white man in Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
.
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
Pompano Beach, Florida
Pompano Beach ) is a city in Broward County, Florida, along the coast of the Atlantic Ocean just to the north of Fort Lauderdale. The nearby Hillsboro Inlet forms part of the Atlantic Intracoastal Waterway. As of the 2010 census, the city's population was 99,845...
. The murder was greeted with outrage in the community 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.
It was not contested that the defendants were held without being able to see a lawyer or be arraigned for a period of a week, or that they were subject 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
Miranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
, 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 appeals to the Florida Court of Appeals was rejected on the grounds that the jury had ruled the confessions had been given voluntarily.
Decision
On February 13, 1940, the court delivered its ruling. The unanimous opinion of the court was delivered by Justice Hugo BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
of Alabama
Alabama
Alabama is a state located in the southeastern region of the United States. It is bordered by Tennessee to the north, Georgia to the east, Florida and the Gulf of Mexico to the south, and Mississippi to the west. Alabama ranks 30th in total land area and ranks second in the size of its inland...
.
This was Marshall's first 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 the defendant to contact anyone, holding them without formal charges or arraignment
Arraignment
Arraignment is a formal reading of a criminal complaint in the presence of the defendant to inform the defendant of the charges against him or her. In response to arraignment, the accused is expected to enter a plea...
, and denying them counsel during questioning were common tactics in law enforcement at the time and were eventually rejected by the court in Miranda v. Arizona
Miranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
(1966).