Summary of Sheppard v. Maxwell
Citation:384 U.S. 333
Relevant Facts: Samuel Sheppard was convicted of second-degree murder for the bludgeoning death of his pregnant wife. Sheppard challenged the verdict on the grounds that he did not receive a fair trial. Sheppard continually maintained his innocence throughout his trial, and alleged that the trial judge permitted prejudicial evidence to be brought in. The Ohio District Court that heard his initial challenge found in his favor, but the Sixth Circuit Court of Appeals reversed the ruling. Sheppard appealed to the Supreme Court, which granted certiorari.
Issues: The legal question presented was whether there is a particular contextual or publicity-oriented level or threshold in which the introduction of prejudicial evidence or information can interfere with a defendant’s Fifth Amendment due process right to a fair trial.
Holding: The Supreme Court ruled in favor of Sheppard.
Reasoning: The Court found that Sheppard was not afforded a fair trial. The Court principally found that the fact that the media broadcasted Sheppard’s confessions, in addition to the proven collaboration between the prosecution and the media, inflamed the jurors’ minds against Sheppard and did not allow him to receive a fair trial. The Court found that the trial judge erred by not postponing the proceedings until a time when the matter bowed out of the media, or to have at least changed the trial venue. Justice Clarke asserted that, “While we cannot say that Sheppard was denied due process by the judge’s refusal to take precautions against the influence of pretrial publicity alone, the court’s later rulings must be considered against the setting in which the trial held. In light of this background, we believe that the arrangements made by the judge with the news media caused Sheppard to be deprived of that ‘Judicial serenity and calm to which [he] was entitled."
Conclusion: This case was significant because the Court found that prejudice can be broad, and encompass activities between the prosecution and the media, rather than only being the introduction of evidence found outside the court.