Citations 309 U.S. 227 (more) | End date 1940 | |
Full case name Chambers et al. v. State of Florida Majority Black, joined by unanimous court Ruling court Supreme Court of the United States Similar Murray v Pearson, Smith v Allwright, McLaurin v Oklahoma State Reg, Shelley v Kraemer, Sweatt v Painter | ||
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.
Contents
Case
The case was argued on January 6, 1940 in front of the court by Thurgood Marshall (who was 32 years old at the time), representing four black men convicted for the murder of a white man in Florida. Marshall would join the court as a justice in 1967.
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.
Decision
On February 13, 1940, the court delivered its ruling. The unanimous opinion of the court was delivered by Justice Hugo Black 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).