Sheppard v. Maxwell Case Brief

Facts of the case

After suffering a trial court conviction of second-degree murder for the bludgeoning death of his pregnant wife, Samuel Sheppard challenged the verdict as the product of an unfair trial. Sheppard, who maintained his innocence of the crime, alleged that the trial judge failed to protect him from the massive, widespread, and prejudicial publicity that attended his prosecution. On appeal from an Ohio district court ruling supporting his claim, the Sixth Circuit Court of Appeals reversed. When Sheppard appealed again, the Supreme Court granted certiorari.

Why is the case important?

An individual was accused of killing his pregnant wife. The media coverage during the trial was overwhelming, to the point of being prejudicial to the defendant.

Question

Whether [the Petitioner] was deprived of a fair trial in his state conviction for the second-degree murder of his wife because of the trial judge’s failure to protect Sheppard sufficiently from the massive, pervasive and prejudicial publicity that attended his prosecution.

ANSWER

The majority recognized that “[l]egal trials are not like elections, to be won through the use of the meeting-hall, the radio, and the newspaper.” Also, “the [Supreme] Court has insisted that no one be punished for a crime without ‘a charge fairly made and fairly tried in a public tribunal free of prejudice, passion, excitement, and tyrannical power.’ Moreover, “[f]reedom of discussion should be given the widest range compatible with the essential requirement of the fair and orderly administration of justice.” However, “it must not be allowed to divert the trial from the ‘very purpose of a court system . . . to adjudicate controversies, both criminal and civil, in the calmness and solemnity of the courtroom according to legal procedures.’ ” One of the requirements is that “the jury’s verdict be based on evidence received in open court, not from outside sources.”

CONCLUSION

The Court concluded that Sheppard did not receive a fair trial consistent with the Due Process Clause of the Fourteenth Amendment . While the Court could not say that Sheppard was denied due process by the trial judge’s refusal to take precautions against the influence of pretrial publicity alone, the trial judge’s later rulings had to be considered against the setting in which the trial was held. In light of this background, the Court believed that the arrangements made by the trial court with the news media caused Sheppard to be deprived of that judicial serenity and calm to which he was entitled. There was no doubt that the deluge of publicity reached at least some of the jury. The trial court did not fulfill his duty to protect Sheppard from the inherently prejudicial publicity that saturated the community and to control disruptive influences in the courtroom.

  • Advocates: –
  • Petitioner: Sheppard
  • Respondent: Maxwell
  • DECIDED BY:Warren Court
  • Location: Southern District Court of Ohio Eastern Division
Citation: 384 US 333 (1966)
Argued: Feb 28, 1966
Decided: Jun 6, 1966
Sheppard v. Maxwell Case Brief