Chandler v. Florida
449 U.S. 560 (1981)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment does not impose a per se constitutional ban on televising criminal trials. To establish a due process violation, a defendant must demonstrate that the media coverage in their specific case resulted in prejudice sufficient to compromise the fairness of their trial.
Facts:
- Noel Chandler and Robert Granger were Miami Beach police officers.
- They were charged with conspiracy to commit burglary, grand larceny, and possession of burglary tools in connection with the break-in of a restaurant.
- The State's principal witness, John Sion, was an amateur radio operator who had coincidentally overheard and recorded conversations between Chandler and Granger on their police walkie-talkie radios during the burglary.
- The novel factors of the case, including the defendants' status as police officers and the unique radio evidence, attracted significant media attention.
- Pursuant to a Florida Supreme Court experimental rule, portions of Chandler and Granger's trial were televised.
- A television camera was present during jury selection, the testimony of the key prosecution witness, and closing arguments.
- A total of two minutes and fifty-five seconds of the trial was broadcast, depicting only the prosecution's case.
Procedural Posture:
- Noel Chandler and Robert Granger were charged with multiple felonies in a Florida state trial court.
- Prior to trial, the defendants moved to have the state's experimental rule allowing television coverage declared unconstitutional; the trial court denied the motion.
- A jury convicted Chandler and Granger on all counts.
- The defendants' post-trial motion for a new trial, based on the alleged unfairness from the television coverage, was denied.
- The defendants appealed to the Florida District Court of Appeal, which affirmed the convictions, finding no evidence of prejudice.
- The Florida Supreme Court denied review.
- The United States Supreme Court granted certiorari to consider the constitutional question.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment prohibit a state from allowing radio, television, and still photographic coverage of a criminal trial for public broadcast, even over the objection of the accused?
Opinions:
Majority - Chief Justice Burger
No. The Constitution does not prohibit a state from experimenting with allowing broadcast coverage of criminal trials, even over a defendant's objection. The prior decision in Estes v. Texas (1965) did not establish a per se constitutional rule forbidding all electronic media coverage of criminal trials; its holding was limited to the specific disruptive and circus-like circumstances of that particular notorious case. We decline to announce such a per se rule now, as there is insufficient empirical evidence to conclude that the mere presence of cameras is inherently prejudicial. Technological advances have made cameras less obtrusive, and principles of federalism allow states to serve as laboratories for procedural experimentation. Florida's program contains safeguards, and the ultimate protection for a defendant is the right to demonstrate with specificity that media coverage in their particular case compromised the jury's fairness or had an adverse impact on trial participants. Appellants in this case made only generalized allegations of prejudice and failed to make such a specific showing.
Concurring - Justice Stewart
I concur in the judgment only. The majority's attempt to distinguish Estes v. Texas is wholly unsuccessful; Estes did, in fact, announce a per se rule that television cameras are prohibited from criminal trials. Rather than trying to unconvincingly differentiate the present case, the Court should simply acknowledge its departure from precedent and flatly overrule Estes.
Concurring - Justice White
I concur in the judgment. I agree with Justice Stewart that Estes is fairly read as establishing a per se rule against televising criminal trials over a defendant's objection, and it should be overruled. I dissented in Estes and remain convinced that televising trials is not inherently prejudicial under properly controlled conditions. By affirming the Florida rule, which contains no exception for sensational cases, the Court is effectively eviscerating Estes, even while claiming consistency. The correct standard is that, absent a specific showing of prejudice to the defense, a conviction should not be overturned simply because the trial was televised.
Analysis:
Chandler v. Florida effectively reverses the broad interpretation of Estes v. Texas, which had been widely understood as creating a constitutional ban on cameras in the courtroom. This decision shifts the legal framework from a potential per se prohibition to a case-by-case analysis that requires the defendant to prove actual prejudice. This ruling paved the way for widespread state adoption of rules permitting electronic media coverage of judicial proceedings, fundamentally altering the landscape of courtroom transparency and media access. It places a significant burden on defendants who wish to exclude cameras, as demonstrating specific, constitutionally significant prejudice is a difficult evidentiary challenge.
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