Sheppard v. Maxwell
|Sheppard v. Maxwell|
|Argued February 28, 1966
Decided June 6, 1966
|Full case name||Sheppard v. Maxwell|
|Citations||384 U.S. 333 (more)
86 S.Ct. 1507, 16 L.Ed.2d 600, 1 Med.L.Rptr. 1220.
|Prior history||Appeal from the Sixth Circuit Court of Appeals|
|Sheppard did not receive a fair trial due to media interference.|
|Majority||Clark, joined by Goldberg, Brennan, White, Warren, Harlan, Stewart, Douglas|
|U.S. Const. amend. I, U.S. Const. amend. VI|
|Wikisource has original text related to this article:|
Sheppard v. Maxwell, 384 U.S. 333 (1966), was a United States Supreme Court case that examined the rights of freedom of the press as outlined in the 1st Amendment when weighed against a defendant's right to a fair trial as required by the 14th Amendment. In particular, the court sought to determine whether or not the defendant was denied fair trial for the second-degree murder of his wife, of which he was convicted, because of the trial judge's failure to protect Sheppard sufficiently from the massive, pervasive, and prejudicial publicity that attended his prosecution.
After suffering a trial court conviction of second-degree murder for the bludgeoning death of his pregnant wife, Sam Sheppard challenged the verdict as the product of an unfair trial. Sheppard, who maintained his innocence of the crime, alleged that the trial judge failed to protect him from the massive, widespread, and prejudicial publicity that attended his prosecution. On appeal from an Ohio district court ruling supporting his claim, the Sixth Circuit Court of Appeals reversed the decision. When Sheppard appealed again, the Supreme Court granted certiorari.
Decision of the Court
In an 8-1 decision the Court found that Sheppard did not receive a fair trial. Noting that although freedom of expression should be given great latitude, the Court held that it must not be so broad as to divert the trial away from its primary purpose: adjudicating both criminal and civil matters in an objective, calm, and solemn courtroom setting. The blatant and hostile trial coverage by Cleveland's radio and print media, and the physical arrangement of the courtroom itself - which facilitated collaboration between the prosecution and present media - all combined to so inflame the jury peoples' minds against Sheppard as to deny him a fair trial. The Court concluded that the trial judge should have either postponed the proceedings or transferred them to a different venue.
In writing for the majority Justice Clark stated:
“While we cannot say that Sheppard was denied due process by the judge’s refusal to take precautions against the influence of pretrial publicity alone, the court’s later rulings must be considered against the setting in which the trial held. In light of this background, we believe that the arrangements made by the judge with the news media caused Sheppard to be deprived of that ‘Judicial serenity and calm to which [he] was entitled.”
Justice Clark continued to cite the shortcomings of the Court in their weak efforts to control the press, and audience. The amount of media coverage this case received was in high volume and as Justice Black says, “The carnival atmosphere at trial could easily have been avoided since the courtroom and courthouse premises are subject to the control of the court."