Chambers v. Florida
|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)|
|Confessions compelled by police through duress are inadmissible at trial.|
|Majority||Black, joined by Hughes, McReynolds, Stone, Roberts, Reed, Frankfurter, Douglas|
|Murphy took no part in the consideration or decision of the case.|
Chambers v. Florida, 309 U.S. 227 (1940), was a landmark 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.
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 appeals to the Florida Court of Appeals were rejected on the grounds that the jury had ruled the confessions had been given voluntarily.
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), a case that Marshall argued as Solicitor General of the United States.