Chambers v. Florida
309 U.S. 227, 60 S. Ct. 472, 1940 U.S. LEXIS 911 (1940)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The use of confessions obtained through psychological coercion and sustained pressure over a prolonged period of interrogation violates the Due Process Clause of the Fourteenth Amendment.
Facts:
- On May 13, 1933, Robert Darsey, an elderly white man, was robbed and murdered in Pompano, Florida, a crime which caused great public outrage.
- Within 24 hours, between 25 and 40 Black men, including petitioners Chambers, Williamson, Davis, and Woodward, were arrested without warrants.
- Fearing mob violence, the sheriff transported some of the prisoners, including Williamson and Chambers, to a different county's jail for one night before returning them.
- For approximately one week, from May 14 to May 20, the suspects were held incommunicado, without access to counsel, friends, or family.
- During this week, the petitioners were repeatedly taken one by one from their cells to a fourth-floor room for questioning by the sheriff, his deputies, and other white citizens.
- Beginning on the afternoon of Saturday, May 20, the questioning became continuous and lasted all night until sunrise on Sunday, May 21.
- After an initial confession from petitioner Woodward was rejected by the State's Attorney as not being "worthwhile," the intensive questioning continued.
- Just after sunrise on May 21, following the all-night interrogation, all four petitioners confessed to the crime.
Procedural Posture:
- Petitioners were convicted of murder in the Broward County Circuit Court (a Florida trial court) and sentenced to death.
- The Florida Supreme Court, the state's highest court, initially affirmed the convictions.
- Petitioners later filed a petition for a writ of error coram nobis, claiming the confessions were coerced. The Florida Supreme Court ordered the issue to be tried before a jury.
- Following a jury verdict against the petitioners, the trial court reaffirmed the sentences; the Florida Supreme Court reversed and ordered a new jury trial on the issue.
- After a change of venue, a second jury again found against the petitioners, and the trial court reaffirmed the death sentences.
- The Florida Supreme Court affirmed this final judgment.
- The United States Supreme Court granted the petitioners' petition for a writ of certiorari to review the judgment of the Florida Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the use of confessions in a capital case violate the Due Process Clause of the Fourteenth Amendment when the confessions were obtained after five days of intermittent questioning of suspects held incommunicado, which culminated in an all-night interrogation session under an atmosphere of public indignation and threat of mob violence?
Opinions:
Majority - Justice Black
Yes, the use of confessions obtained under these circumstances violates the Due Process Clause of the Fourteenth Amendment. The Court must independently review the facts to determine whether a confession was obtained by means proscribed by the Due Process Clause. The undisputed facts show that compulsion was applied through protracted and persistent questioning in an environment calculated to break the strongest nerves. The circumstances of the petitioners' confinement—including dragnet arrests, isolation from counsel or friends, the constant threat of mob violence, and a week of interrogations culminating in an all-night vigil—were inherently coercive. To allow a conviction based on confessions procured through such methods would render the constitutional guarantee of due process a meaningless symbol. The Constitution forbids such lawless police conduct, regardless of the end it seeks to achieve.
Analysis:
This case significantly broadened the scope of what constitutes a coerced confession under the Fourteenth Amendment's Due Process Clause. Moving beyond the physical brutality standard established in Brown v. Mississippi, Chambers established that intense psychological pressure and inherently coercive interrogation environments are sufficient to render a confession involuntary. The decision solidified the 'totality of the circumstances' test for voluntariness and affirmed the Supreme Court's authority to make an independent determination of the facts when a fundamental constitutional right is at stake. This precedent became a cornerstone of modern confession law, influencing subsequent decisions regarding suspects' rights during custodial interrogation.
Unlock the full brief for Chambers v. Florida