Alcorta v. Texas
1957 U.S. LEXIS 188, 2 L. Ed. 2d 9, 355 U.S. 28 (1957)
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Rule of Law:
A State's knowing use of false testimony, or allowing false testimony to stand uncorrected, that is material to the defense and could influence the jury's verdict, constitutes a denial of due process under the Fourteenth Amendment.
Facts:
- Alvaro Alcorta killed his wife by stabbing her to death.
- Alcorta claimed the killing occurred in a fit of sudden passion after he discovered his wife kissing Natividad Castilleja late at night in a parked car, a defense that could reduce the charge to murder without malice under Texas law.
- Castilleja, the only eyewitness, testified for the State, stating his relationship with Alcorta's wife was merely a casual friendship and denying any romantic involvement or dates other than giving her rides home from work.
- Prior to the trial, Castilleja confessed to the prosecutor that he had engaged in sexual intercourse with Alcorta's wife on five or six occasions shortly before her death.
- The prosecutor instructed Castilleja not to volunteer information about their sexual relationship but to answer truthfully if specifically asked, and did not disclose this information to Alcorta or his defense counsel.
- Castilleja's trial testimony directly refuted Alcorta's defense that he had found his wife embracing Castilleja, creating the impression of a casual encounter rather than an intimate relationship and undermining the 'sudden passion' claim.
Procedural Posture:
- Alvaro Alcorta was indicted for murder in a Texas state trial court.
- A jury found Alcorta guilty of murder with malice and sentenced him to death.
- The Texas Court of Criminal Appeals affirmed the judgment and sentence.
- After his conviction was affirmed, Castilleja issued a sworn statement admitting he had given false testimony at trial.
- Alcorta filed a petition for a writ of habeas corpus in the trial court, contending he was denied a fair trial because Castilleja had testified falsely with the prosecutor's knowledge.
- The trial court held a hearing, where both Castilleja and the prosecutor admitted to the prior disclosure of the illicit relationship, and subsequently denied the petition.
- Alcorta then applied to the Texas Court of Criminal Appeals for a writ of habeas corpus, which also refused to issue the writ based on the trial court's record.
- The U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does the State's knowing use of false testimony, where a prosecutor allows a witness to give a materially false impression to the jury without correction, violate a defendant's due process rights under the Fourteenth Amendment?
Opinions:
Majority - Per Curiam
Yes, the State's knowing use of false testimony that gives a materially false impression to the jury without correction violates a defendant's due process rights. The Court found that Castilleja's testimony, taken as a whole, gave the jury the false impression that his relationship with Alcorta's wife was nothing more than that of casual friendship. This testimony was elicited by the prosecutor who knew of the illicit sexual relationship between Castilleja and Alcorta's wife. The Court concluded that this testimony was seriously prejudicial to Alcorta because it squarely refuted his defense that he killed his wife in a 'sudden passion arising from an adequate cause,' which could have reduced his charge to 'murder without malice' and precluded the death penalty. Had Castilleja's relationship been truthfully portrayed, it would have corroborated Alcorta's contention about finding his wife embracing Castilleja and would have also impeached Castilleja's credibility. Relying on the principles established in Mooney v. Holohan and Pyle v. Kansas, the Court held that Alcorta was not accorded due process of law.
Analysis:
This case solidifies the principle that prosecutors have an affirmative duty to ensure the integrity of testimony presented in court. It reinforces that the knowing presentation or allowance of false testimony, even by omission or by creating a false impression, is a violation of due process if it is material to the outcome. Alcorta expands the scope of prosecutorial misconduct to include situations where prosecutors facilitate misleading testimony, rather than just explicitly suborning perjury, particularly when it undermines a defendant's core defense. This ruling emphasizes the constitutional requirement of a fair trial and the state's obligation to seek justice, not merely a conviction.
