Holbrook v. Flynn

PETITIONER: Holbrook
RESPONDENT: Flynn
LOCATION: Heath Residence

DOCKET NO.: 84-1606
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the First Circuit

CITATION: 475 US 560 (1986)
ARGUED: Jan 14, 1986
DECIDED: Mar 25, 1986

ADVOCATES:
George Kannar - on behalf of Respondent
Thomas More Dickinson - on behalf of the Petitioners

Facts of the case

The situation discussed in this case study is centered around the charges for armed robbery. The respondent and a few other people who helped him in this crime were held without bail. As the first trial started, the front row of the court room was occupied by the state troopers with weapon. Their presence was motivated by the fact that the criminals were very dangerous, so the troopers were present for the security reasons.

The counsel was confident that such watch was unnecessary, so he protested their presence. The judges did not find this complaint reasonable and declined the claim. The case brief shows that eventually Flynn was sentenced during this trial. Later, the respondent brought a habeas corpus proceeding in Federal District Court, but the claim against the presence of state troopers was declined again.

This decision was reversed by the appellate judges, who admitted that all the previous judges did not take into account whether the specific circumstances of this trial were appropriate for such level of protection and whether this treatment was appropriate. Moreover, such armed watch had a very bad consequences for the respondent because it created unnecessary prejudice against the people under trial. It would be almost impossible to decide in favor of respondents under such circumstances. It is important to add that it was almost impossible to have been taken as a sign of anything other than a normal official concern for the safety and order of the proceedings, especially given that there were involved six defendants. All in all, the final decision of the judges was consensual as the court approved the presence of four troopers.

Question

Media for Holbrook v. Flynn

Audio Transcription for Oral Argument - January 14, 1986 in Holbrook v. Flynn

Warren E. Burger:

Mr. Dickinson, I think you may proceed whenever you are ready.

Thomas More Dickinson:

Thank you, Mr. Chief Justice, and may it please the Court:

This is the case of Holbrook v. Moran... Holbrook and Moran v. Flynn which is here on a writ of certiorari to review a decision of the United States Court of Appeals for the First Circuit, which court granted a writ habeas corpus to Charles Flynn.

The question before the Court today is whether the First Circuit committed error in concluding that the presence of armed Rhode Island State Troopers in the courtroom during Flynn's trial deprived Flynn of a fair trial by interfering with his presumption of innocence.

Warren E. Burger:

How many defendants were there being tried at that time?

Thomas More Dickinson:

Mr. Chief Justice, there were six defendants on trial at the time this case went to trial in Providence, Rhode Island.

Three of the defendants... all defendants were on trial together.

Three of them were acquitted.

Flynn and two co-defendants were convicted.

In my argument today--

William J. Brennan, Jr.:

Are you going to tell us exactly where the officers were in relation to the defendants in the courtroom?

Thomas More Dickinson:

--Your Honor, the record--

William J. Brennan, Jr.:

Were they behind the chairs in which defendants were sitting or where?

Thomas More Dickinson:

--Your Honor, it would appear that the record does not specifically reflect where the officers were at all points in time.

It is my understanding, however, Your Honor, that the state troopers were located in the front row of the spectator section of the courtroom.

William J. Brennan, Jr.:

As, for example, we have a counsel side here and a... beyond it, a spectator section.

Thomas More Dickinson:

That is correct, Your Honor.

William J. Brennan, Jr.:

Is that the way it is?

Thomas More Dickinson:

And if I were to use this courtroom as an illustration, I think it would be a perfect illustration.

The defendants would be seated in the back row of the counsel section with their attorneys--

William J. Brennan, Jr.:

Yes.

Thomas More Dickinson:

--And the troopers would be seated in the front row of the spectator section behind, if you will, the bar, what we refer to in Rhode Island as the bar.

Byron R. White:

But directly behind that, behind the defendants, or does the record show?

Thomas More Dickinson:

The record does not specifically address where they were.

Byron R. White:

It could be they were on the other side of the front row?

Thomas More Dickinson:

It's unquestioned, Your Honor, that they were seated in the front row of the spectator section.

Byron R. White:

But they might have been on the other side of the room from the defendants.

Thomas More Dickinson:

They might have been.

The record would not reflect such a finding.

It would appear--