Miller v. Pate
17 L. Ed. 2d 690, 1967 U.S. LEXIS 2259, 386 U.S. 1 (1967)
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Rule of Law:
The Fourteenth Amendment's Due Process Clause prohibits a state criminal conviction that is obtained through the prosecution's knowing use of false evidence, as such conduct renders the trial fundamentally unfair.
Facts:
- On November 26, 1955, an eight-year-old girl died in Canton, Illinois, as a result of a brutal sexual attack.
- Lloyd Eldon Miller, Jr. was charged with the girl's murder, and there were no eyewitnesses to the crime.
- Three days after the murder, a pair of men’s underwear shorts covered with reddish-brown stains were found by a policeman in the Van Buren Flats, about a mile from the crime scene.
- The prosecution's theory was that Miller had been wearing these shorts when he committed the murder and had afterwards removed and discarded them.
- Evidence was presented at trial that the victim had type 'A' positive blood, and Miller's blood was group 'O.'
- A state chemist testified that the stains on the shorts were human blood of group 'A,' and the prosecutor repeatedly emphasized this in arguments to the jury.
- During a later federal habeas corpus proceeding, the stained shorts were examined by a chemical micro-analyst, who determined that the reddish-brown stains were paint, not blood, and found no traces of human blood.
- It was established that prosecution counsel knew at the time of Miller's trial that the shorts were stained with paint, and the police had a memorandum attempting to explain the presence of paint.
- Miller was a taxi driver, not a painter.
Procedural Posture:
- Prior to his trial in an Illinois court, Lloyd Eldon Miller, Jr.'s counsel filed a motion for an order permitting a scientific inspection of the physical evidence the prosecution intended to introduce.
- The Illinois trial court denied Miller's motion.
- A jury trial in Illinois resulted in a verdict of guilty and a sentence of death for Miller.
- The Supreme Court of Illinois affirmed the judgment of conviction.
- On the basis of leads developed at a subsequent unsuccessful state clemency hearing, Miller applied to a federal district court for a writ of habeas corpus.
- After a hearing, the federal district court granted the writ and ordered Miller’s release or prompt retrial.
- The Court of Appeals for the Seventh Circuit reversed the district court's decision, denying the writ of habeas corpus.
- The Supreme Court of the United States granted certiorari to consider the constitutional validity of Miller's trial.
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Issue:
Does a state criminal conviction obtained by the prosecution's knowing use of false evidence violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Stewart
Yes, a state criminal conviction obtained by the prosecution's knowing use of false evidence violates the Due Process Clause of the Fourteenth Amendment. The Court reaffirmed the long-established principle, first articulated in Mooney v. Holohan, that the Fourteenth Amendment cannot tolerate a state criminal conviction secured by the knowing use of false evidence. In this case, the prosecution consistently and repeatedly misrepresented People's Exhibit 3 (the shorts) as 'a garment heavily stained with blood' even though it knew the stains were paint. The prosecution's entire theory of the case hinged on this misrepresentation, as the discovery of paint-stained shorts a mile from the crime scene would be 'virtually valueless as evidence' against Miller, a taxi driver. Conversely, the 'blood stained shorts' were 'a vital component' and 'important link in the chain of circumstantial evidence,' carrying an 'incalculable' and gruesomely emotional impact on the jury. The Court found the prosecution's subsequent claim that 'everybody' knew the shorts were paint-stained to be 'totally belied by the record.' This deliberate misrepresentation of the truth fundamentally undermined the fairness of the trial, rendering the conviction unconstitutional.
Analysis:
This case is a foundational reaffirmation of the due process right to a fair trial, particularly highlighting the constitutional prohibition against prosecutorial misconduct involving the knowing use of false evidence. It solidifies the principle that the integrity of the judicial process demands honesty from the state's attorneys, reinforcing the idea that a conviction obtained by deceit cannot stand. The ruling serves as a vital precedent for defendants seeking to overturn convictions where material evidence was intentionally misrepresented or fabricated by the prosecution. It underscores the judiciary's role in safeguarding against governmental overreach and ensuring trials are based on truth rather than deception.
