Law School Case Brief
Williams v. New York - 337 U.S. 241 (1949)
The Supreme Court of the United States cannot say that the due process clause renders a sentence void merely because a judge gets additional out-of-court information to assist him in the exercise of the awesome power of imposing the death sentence.
After a trial in New York state court, defendant Samuel T. Williams was convicted of first-degree murder for a killing that occurred during a robbery. At sentencing, the jury recommended life imprisonment, but the trial court imposed the death sentence. In sentencing Williams, the trial court considered not only the evidence produced at trial, but also additional information obtained through the trial court's probation department and through other sources, as permitted by state statute. The Court of Appeals of New York affirmed the conviction, rejecting Williams' argument that the statute violated his Fourteenth Amendment due process rights in that the death sentence was based upon information supplied by witnesses with whom Williams had not been confronted and as to whom he had no opportunity for cross-examination or rebuttal. Williams appealed.
Did the trial court's consideration of a probation report at sentencing violate Williams' right to due process?
The Supreme Court of the United States affirmed the judgment of the Court of Appeals of New York. The Court ruled that the Due Process Clause did not prevent the trial court from considering the probation report in sentencing Williams, given the historical background and practical reasons for the different evidentiary rules governing trials and sentencing procedures. The probation report, which drew on information concerning every aspect of Williams' life, was invaluable to the trial court in making its sentencing decision, and given the type and extent of information included in the report, it would have been impractical if not impossible to have presented it in open court with cross-examination.
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