Chambers v. Mississippi Case Brief

Why is the case important?

Defendant, Leon Chambers, was convicted for the murder of a police officer, Aaron Liberty. As part of his defense, Defendant attempted to admit evidence that another man, Gable McDonald, committed the murder.

Facts of the case

Leon Chambers was charged with murdering a policeman. Another man, Gable McDonald, confessed to the murder, in addition to confession to third parties, and was taken into custody. One month later, McDonald denied the confession and was released from custody. At trial, Chambers tried to prove McDonald admitted to the crime several times and confessed to third parties. The district court found the evidence of the confessions was inadmissible because of the voucher rule – a common-law rule that prohibits the defense from cross-examining a witness when the prosecution failed to do so – and the fact that the statements were hearsay. Chambers’ appealed and argued that the district court violated the Due Process Clause of the Fourteenth Amendment by refusing to admit the evidence.

Question

There are two evidentiary issues presented in this case.
The first issue is whether Mississippi, under the state voucher rule, can prevent Defendant from cross-examining McDonald.

Answer

The United States Supreme Court made the following holdings.
The Court held that the state’s common-law voucher rule (so-called because the presumption is that a party vouches for the credibility of its witness) violated Defendant’s constitutional right to due process, specifically the right to confront witnesses. The rule is archaic and is not compatible with the criminal court process. There also is no doubt that McDonald is an adverse witness since any testimony on his behalf to clear his own name directly affects the ability of Defendant to clear his name.

Conclusion

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.

  • Case Brief: 1973
  • Petitioner: Leon Chambers
  • Respondent: Mississippi
  • Decided by: Burger Court

Citation: 410 US 284 (1973)
Argued: Nov 15, 1972
Decided: Feb 21, 1973