Summary of Chambers v. Mississippi, 410 U.S. 284 (1973)
Relevant Facts: As the police were attempting to arrest a youth, the local crowd sought to prevent them. Someone shot a police officer, who in turn shot the Df. The officer later died and the Df was arrested. A third person confessed to the killing under oath, but later repudiated. However, he also confessed to three of his friends. At trial the Df was barred from showing the jury the confession and was not permitted to call the declarant as a hostile witness for impeachment. The declarant’s three friends, although permitted to testify, their testimony was taken outside the presence of the jury.
Legal Issue(s): Whether the exclusion of the confession and the corroborating statements by the declarant’s friends, in conjunction with the State’s action denying the Df the opportunity to question its witness constituted a denial of the Df’s Due Process Rights?
Court’s Holding: The exclusion of the evidence, coupled with the State’s refusal to permit the Df to cross-examine the declarant of a confession made under oath, denied the Df a trial in accord with traditional and fundamental standards of due process.
Procedure: Jury trial conviction for murder–sentenced to life; MS S.Ct. Affirmed; U.S. S.Ct. Reversed and Remanded.
Law or Rule(s): 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.
Court Rationale: Df was denied the opportunity to subject the witness’ damning repudiation and alibi to cross-examination. He was not allowed to test the witness’ recollection, to probe into the details of his alibi, or to ‘sift’ his conscience so that the jury could judge for itself whether it was trustworthy or not. Confrontation help assure the “accuracy of the truth-determining process," which is “an essential and fundamental requirement" for a fair trial. The trial ct’s refusal to allow Df to introduce the testimony of the three friends was in error. Under circumstances that assure reliability and thereby compensate for the absence of an oath and opportunity to cross-examine, declarations against interest are an exception to hearsay. This exception is founded on the assumption that a person is unlikely to fabricate a statement against his own interests at the time it was made. The hearsay statements made and offered at trial provided considerable assurances of reliability. The confessions were made spontaneously to a close acquaintance shortly after the crime, and each one was corroborated by other evidence. Each confession was self-incriminating and unquestionably against interest. If there were questions about the truth of the statements made out of ct, the declarant was available at trial.