Chambers v. Mississippi

PETITIONER: Leon Chambers
RESPONDENT: Mississippi
LOCATION: Wilkinson Circuit Court, Mississippi

DOCKET NO.: 71-5908
DECIDED BY: Burger Court (1972-1975)
LOWER COURT: Supreme Court of Mississippi

CITATION: 410 US 284 (1973)
ARGUED: Nov 15, 1972
DECIDED: Feb 21, 1973

ADVOCATES:
Peter Westen - for petitioner, pro hac vice, by special leave of Court
Timmie Hancock - for respondent

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

Is there a violation of the Due Process Clause of the Fourteenth Amendment when the defendant cannot cross-examine a witness or admit the testimony of another person’s confession of the crime to a third party?

Media for Chambers v. Mississippi

Audio Transcription for Oral Argument - November 15, 1972 in Chambers v. Mississippi

Warren E. Burger:

We'll hear arguments next in 71-5908, Chambers against Mississippi.

Mr. Westen?

Peter Westen:

Mr. Chief Justice, may it please the Court.

The petitioner in this case, Leon Chambers was convicted of a murder which another man was seen committing and towards that other man spontaneously and repeatedly confessed within hours of the shooting.

The case presents two questions.

First, whether Chambers has a right under the constitution to introduce the other man's confessions to prove he is innocent and second, whether Chambers has a right under the constitution to cross-examine the other man and to impeach him for repudiating his confession in court and denying that he had anything to do with the crime.

The case began with a shooting that it took place at night during a racial disturbance in June, 1969 in the town of Woodville, Mississippi.

The victim was a policeman named Aaron Liberty.

Liberty and other policemen were confronting an angry crowd of about 50 blacks.

As Liberty faced the crowd, he was suddenly shot four times in the back.

The bullets came from a 22-caliber gun from somewhere in the alley behind him.

As he died, he turned and shot both barrels of his riot gun into the alley.

The first shot passed over the heads of the crowd, the second shot hit a man, who by then was running down the alley.

That man was the petitioner, Leon Chambers.

Chambers was left in the alley severely wounded.

When the police had gone, he was taken to a local hospital where two days later, he was placed under-arrest for the murder of Aaron Liberty.

Chambers insisted from the outset that he was innocent and that the state had arrested the wrong man.

Indeed, within hours of shooting, another man Gable McDonald spontaneously confessed on separate occasions to three different people that he was the one who shot officer Liberty.

He first confessed to Berkley Turner, who left the scene of the shooting with him, that night.

He next confessed to Sam Hardin who he had known all of his life and who drove him home on the night of the shooting.

He confessed the next day to Albert Carter, his next door neighbor whom he had known for at least 25 years.

Four months later, McDonald repeated his confession.

He dictated it in the presence of a Minister and signed it under oath, it was detailed.

He said that he shot officer Liberty at close range from the mouth of the alley.

He said that he used his own nine-shot 22-caliber pistol which he discarded after the shooting.

He said that he was confessing because it was no secret any longer that he was the one that shot Liberty.

He said that he was telling the truth, but admitted that he would be afraid to testify in court.

Harry A. Blackmun:

Mr. Westen, does the record show what has happened to Gable McDonald then?

Peter Westen:

Gable McDonald had a preliminary hearing, one month after he signed his written confession for justice of the peace who after a few days of deliberation, dismissed the charges against him.

One year later, Chambers himself went to trial for the murder of Aaron Liberty.