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Sleepy Lagoon Trials: 1942-43

"tangible And Substantial Evidence Is Woefully Lacking"

The Sleepy Lagoon Defense Committee's efforts were successful on October 4, 1944, when the three-judge 2nd District Court of Appeal unanimously reversed all the guilty verdicts. The court rejected the appellants' contention that Diaz might have been killed by a car or a fall, citing autopsy evidence that he had died from a brain hemorrhage brought on by a blow to the head with an instrument. The court ruled that criminality was involved in Diaz's death. Yet they found no evidence in the 6,000-page trial transcript that connected any of the Sleepy Lagoon defendants to Diaz's death. Apart from one defendant tied to a stabbing during the Delgadillo "free for all" only by inconsistent identifications, the judges similarly found no evidence connecting the defendants with armed assaults. The reversal also ruled that testimony in which several of the accused implicated their codefendants should have been stricken as hearsay and noted that police did not dispute that some of the statements were elicited by jailhouse beatings.

The court agreed that the defendants had returned to Sleepy Lagoon intending to have a fist fight with the youths who had attacked them and their friends. The indictments, however, specifically charged them with conspiring to invade the Delgadillo home with weapons, intending to commit murder. As such, the indictments did not apply to the facts of the case.

While the court ruled that "tangible and substantial evidence" was "woefully lacking," it also extensively criticized Judge Fricke's sarcastic and dictatorial conduct of the trial. "Constant bickering and quarreling with counsel by the court was not conducive to the creation of judicial atmosphere," agreed the appellate judges. Judge Fricke had "materially injured" the defendants' right to a fair trial by denigrating the professional ethics of the defense attorneys and berating their conduct "when in most instances, not even a mild rebuke was deserved." Fricke's multiple errors included a decree that lack of space was an acceptable reason for preventing the five defense lawyers from conferring or even sitting with their clients in the courtroom. If a room is too small for proper trial proceedings, said the appeal decision, "it is not the Constitution or the rights guaranteed by it that must yield."

The court, in agreement with California's attorney general and the defense lawyers, dispensed with a customary waiting period before deeming the original verdict excessive. Facing a unanimous appellate decision and lacking any new evidence to justify a new trial, the Los Angeles district attorney declined to prosecute the case a second time. After experiencing one of the most criticized trials in Los Angeles history and a year in San Quentin penitentiary, the Sleepy Lagoon defendants were released and their records were cleared. The trial was the inspiration for Luiz Valdez's acclaimed 1978 play Zoot Suit and his 1981 film of the same name.

Tom Smith

Suggestions for Further Reading

"Conviction of 12 Reversed in Sleepy Lagoon Murder." Los Angeles Times (October 5, 1944): 1.

Kinloch, John. "Mexicans Face Police Terror Round-Ups; Vile Press Slurs." California Eagle (November 5, 1942): IA, 7B.

Maz6n, Mauricio. The Zoot Suit Riots. Austin: University of Texas Press, 1984.

Tobar, Hector. "Sleepy Lagoon Victims Laud Their Champion." Ldos Angeles Times (April 20, 1997): B-1.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1941 to 1953Sleepy Lagoon Trials: 1942-43 - Zoot Suit Riots, "tangible And Substantial Evidence Is Woefully Lacking", Suggestions For Further Reading