Other Free Encyclopedias :: Law Library - American Law and Legal Information :: Great American Court Cases Vol 6

Chambers v. Florida - Further Readings

Petitioners
Isiah (Izell) Chambers, Jack Williamson, Charlie Davis, Walter Woodward (Woodard)
Respondent
State of Florida
Petitioners' Claim
Four black men sentenced to death for the murder of a white man claimed theirconvictions were obtained "solely upon confessions and pleas of guilt extorted by violence and torture" in violation of the Fourteenth Amendment.
Chief Lawyers for Petitioners
Leon A. Ransom, S. D. McGill, Thurgood Marshall
Chief Lawyers for Respondent
Tyrus A. Norwood
Justices for the Court
Hugo Lafayette Black (writing for the Court), Pierce Butler, William O. Douglas, Felix Frankfurter, Charles Evans Hughes, James Clark McReynolds, StanleyForman Reed, Owen Josephus Roberts, Harlan Fiske Stone
Justices Dissenting
None (Frank Murphy did not participate)
Place
Washington, D.C.
Date of Decision
12 February 1940
Decision
The unanimous Court threw out verdicts of murder against the four black men handed down by two juries.
Significance
Chambers v. Florida was the first case in which the Court unequivocally declared the Fourteenth Amendment meant state courts would have to observedue process of law. Henceforth, state prosecution methods used in obtaining convictions would be subject to Supreme Court review, and the Fourteenth Amendment would be used to further individual rights for all.
On 13 May 1933, Robert Darsey, an elderly white man, was robbed and murdered.Within 24 hours, between 25 and 40 African Americans--the exact number was never determined--were arrested without warrants and held in the Broward County jail. Over the next six days, the men were individually questioned by teamsof four to ten police officers without any opportunity to talk to lawyers, relatives, or friends.
By 20 May, police attention focused on Isiah Chambers, Jack Williamson, Charlie Davis and Walter Woodward. "Sometime in the early hours of Sunday, the 21st, Woodward apparently `broke,'" Justice Black wrote in his summation. So didthe others "one right after the other," and the state's attorney was summoned from bed. When, however, he read Woodward's confession, he said, "Tear thispaper up, that isn't what I want, when you get something worthwhile call me." State officials renewed the questioning into the next morning. That's whenthey got "something `worthwhile' which the state's attorney would `want,'" Justice Black wrote.
For six days, the four had been questioned under circumstances "calculated tobreak the strongest nerves and the stoutest resistance" and to "fill petitioners with terror and frightful misgivings." Black observed:
The haunting fear of mob violence was around them in an atmosphere charged with excitement and public indignation.
The four "broke" only under "therelentless tenacity" of their interrogators. Judge Harlan was:
.. . not impressed with the argument that law enforcement methods such as these are necessary to uphold our laws. The Constitution proscribes such lawlessmeans irrespective of the end. And this argument flouts the basic principlethat all people must stand on an equality before the bar of justice in everyAmerican court.

Then, at a time when news of Nazi victories were daily headlines, Black concluded:
Today, as in ages past, we are not without tragic proof thatthe exalted power of some governments to punish manufactured crime dictatorially is the handmaid of tyranny. Under our constitutional system, courts stand against any winds that blow as havens of refuge for those who might otherwise suffer because they are helpless, weak, outnumbered, or because they are nonconforming victims of prejudice and public excitement. Due process of law,preserved for all by our Constitution, commands that no such practice as thatdisclosed by this record shall send any accused to his death. No higher duty, no more solemn responsibility, rests upon this Court than that of translating into living law and maintaining this constitutional shield deliberately planned and inscribed for the benefit of every human being subject to our Constitution--of whatever race, creed or persuasion.

Black later recalled, "There's been no case which I put more work in." He didnot want to write the decision and had even voted against the Court hearingit, fearing the decision would go the wrong way. Chief Justice Hughes assigned the case "to me because I was a Southerner," Black said:
And there were these Negroes here who were so mistreated. He forced me to write thecase. At first I didn't want to. He said, "Don't worry, I'll get the Court for you." So I saved all my views and wrote them since I knew I had the whole Court with me.

Black wrote his opinion within two weeks after oral arguments were heard on 4January 1940, and circulated it among his fellow justices. Justices McReynolds and Reed had considered dissenting, but changed their minds. Chief JusticeHughes rescheduled the announcement of the decision from 5 February to 12 February. On Lincoln's Birthday, 1940, the former member of the Ku Klux Klan delivered his opinion in open court--"one of the enduring utterances in the history of the Supreme Court and in the annals of human freedom," Justice Frankfurter wrote in a letter to his wife.
Florida officials scheduled another trial for the four prisoners, but they made what the same Florida officials called an "escape" and were never recaptured.
Impact
The decision was written by a justice whose appointment to the Supreme Courthad been hotly controversial because of his membership, as a youth, in the KuKlux Klan. But after Chambers v. Florida, Justice Black emerged as perhaps the Court's most forceful defender of civil rights.
The decision was "far and away the most direct, sweeping and brilliantly written application of the Fourteenth Amendment to human rights that has come from our highest Court," the New York Times declared at the time. The appeal, one of the first brought by the newly established Legal Defense Fund ofthe NAACP headed by Thurgood Marshall, "will ring with power as long as liberty and justice are cherished in our land." So said the usually cynical historian Charles Beard. A gratified Franklin Delano Roosevelt, still smarting overcriticism over Black's appointment, slyly suggested the press should not just "give a little praise," but add a "modicum of apology for things they havesaid in the last two years. Is that fair enough?"
Related Cases

  • Gallegos v. Colorado, 370 U.S. 49 (1962).
  • Miller v. Fenton, 741 F.2D 1456, (3rd Cir. 1984).

User Comments Add a comment…

Louisiana ex rel. Francis v. Resweber - Further Readings [next] [back] Hurtado v. California - Further Readings