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Chambers v. Florida


Chambers v. Florida was the first case in which the Court unequivocally declared the Fourteenth Amendment meant state courts would have to observe due 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 teams of 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 did the 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 this paper 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 when they got "something `worthwhile' which the state's attorney would `want,'" Justice Black wrote.

For six days, the four had been questioned under circumstances "calculated to break 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 "the relentless 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 lawless means irrespective of the end. And this argument flouts the basic principle that all people must stand on an equality before the bar of justice in every American 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 that the 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 that disclosed 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 did not want to write the decision and had even voted against the Court hearing it, 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 the case. 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 4 January 1940, and circulated it among his fellow justices. Justices McReynolds and Reed had considered dissenting, but changed their minds. Chief Justice Hughes 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.

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Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1918 to 1940Chambers v. Florida - Significance, Impact, Further Readings