Law School Case Brief
Williams v. Florida (1970) - 399 U.S. 78, 90 S. Ct. 1893 (1970)
The defendant in a criminal trial is frequently forced to testify himself and to call other witnesses in an effort to reduce the risk of conviction. When he presents his witnesses, he must reveal their identity and submit them to cross-examination which in itself may prove incriminating or which may furnish the State with leads to incriminating rebuttal evidence. That the defendant faces such a dilemma demanding a choice between complete silence and presenting a defense has never been thought an invasion of the privilege against compelled self-incrimination. The pressures generated by the State's evidence may be severe but they do not vitiate the defendant's choice to present an alibi defense and witnesses to prove it, even though the attempted defense ends in catastrophe for the defendant. However "testimonial" or "incriminating" the alibi defense proves to be, it cannot be considered "compelled" within the meaning of the Fifth and Fourteenth Amendments.
Prior to his trial for robbery in the state of Florida, petitioner filed a motion, which was subsequently denied, for a protective order in which he sought to be excused from the requirements of Fla. R. Crim. P. 1.200. Pursuant to that rule, a defendant is required, on the written demand of the prosecutor, to give notice in advance of trial of his intention to claim an alibi and to furnish information as to the place where he would claim to have been and with the names and addresses of the alibi witnesses he intended to use. Petitioner claimed the rule required him to be a witness against himself in violation of his U.S. Const. amend. V and XIV rights. Petitioner also argued that the denial of his motion to impanel a 12-man jury instead of the six-man jury provided by Florida law in such cases, was a violation of his U.S. Const. amend. V and VI rights. Petitioner was convicted of robbery, the conviction of which was affirmed by the District Court of Appeal (Florida). The United States Supreme Court granted the petition for certiorari review.
Were the requirements of Fla. R. Crim. P. 1200 a violation of the petitioner’s right against self-incrimination?
The judgment was affirmed as to the Florida criminal procedure statute because the Supreme Court concluded that the privilege against self-incrimination had not been violated. In arriving at that conclusion, the Court noted that the statute did not compel defendants, such as petitioner, to give any such information. The judgment was also affirmed as to the jury issue because a 12-man panel was not a necessary ingredient of trial by jury.
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