Chambers v. Miss.

Case Summary

Procedural Posture

The state supreme court (Mississippi) affirmed defendant's conviction for the murder of a policeman. The U.S. Supreme Court granted certiorari to consider whether defendant's trial was conducted in accord with principles of due process under U.S. Const. amend. XIV in light of the trial court's failure to allow defendant to cross-examine a key witness and the exclusion of exculpatory evidence by application of the hearsay rule.

Overview

Defendant was convicted of murdering a policeman. The state supreme court affirmed the judgment. The Court granted certiorari to consider whether defendant's trial was conducted in accord with principles of due process under the U.S. Const. amend. XIV in light of the trial court's failure to allow defendant to cross-examine a key witness and the exclusion of evidence by application of the state hearsay rule. The Court reversed defendant's conviction. It held that the exclusion, under state hearsay rules, of exculpatory testimony that another party had committed the crime, which under the circumstances was likely to be trustworthy and within the rationale of the exception for declarations against penal interest, coupled with the State's refusal to allow defendant to cross-examine a key witness because of a common-law rule that a party may not impeach his own witness, denied him a trial in accord with fundamental standards of due process.

Outcome

The court reversed defendant's conviction.

LexisNexis^® Headnotes

Constitutional Law > ... > Fundamental Rights > Criminal Process > Right to Confrontation

Criminal Law & Procedure > Trials > Defendant's Rights > Right to Due Process

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

HN1  Criminal Process, Right to Confrontation

The right of an accused in a criminal trial to due process is, in essence, the right to a fair opportunity to defend against the State's accusations. The rights to confront and cross-examine witnesses and to call witnesses in one's own behalf are essential to due process. A person's right to reasonable notice of a charge against him, and an opportunity to be heard in his defense--a right to his day in court--are basic in our system of jurisprudence; and these rights include, as a minimum, a right to examine the witnesses against him, to offer testimony, and to be represented by counsel.

Constitutional Law > ... > Fundamental Rights > Criminal Process > Right to Confrontation

Evidence > ... > Impeachment > One's Own Witnesses > General Overview

HN2  Criminal Process, Right to Confrontation

The right to confront and to cross-examine is not absolute and may, in appropriate cases, bow to accommodate other legitimate interests in the criminal trial process, but its denial or significant diminution calls into question the ultimate integrity of the fact-finding process and requires that the competing interest be closely examined.

Criminal Law & Procedure > Trials > Witnesses > Presentation

Criminal Law & Procedure > Trials > Burdens of Proof > Prosecution

HN3  Witnesses, Presentation

Few rights are more fundamental than that of an accused to present witnesses in his own defense. In the exercise of this right, the accused, as is required of the state, must comply with established rules of procedure and evidence designed to assure both fairness and reliability in the ascertainment of guilt and innocence.