People v. Adamson
27 Cal. 2d 478, 165 P.2d 3 (1946)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state constitutional provision allowing a court and prosecutor to comment on a criminal defendant's failure to explain or deny evidence against them, and allowing the jury to consider that failure, does not violate the Due Process Clause of the Fourteenth Amendment. Such failure does not create a presumption of guilt but may be considered by the jury as tending to indicate the truth of such evidence and that unfavorable inferences drawn from it are more probable.
Facts:
- On July 24, 1944, Stella Blauvelt, a 64-year-old widow, was beaten and strangled to death with a lamp cord in her Los Angeles apartment.
- Investigators determined the murderer likely gained entry by forcing open an inner door leading from a garbage compartment into the kitchen.
- Six fingerprints belonging to the defendant, Adamson, were found on this unhinged inner door.
- Valuable diamond rings that Blauvelt was known to wear were missing from her body and could not be found in the apartment.
- A witness testified that several weeks after the murder, she overheard Adamson ask an unidentified person if he was interested in buying a diamond ring.
- The tops of three women's stockings, tied into knots, were found in Adamson's room; one of the victim's stockings had been removed and its top part torn off, with the other stocking missing entirely.
- When questioned by police, Adamson gave false addresses for his residence and refused to look at a picture of the victim.
Procedural Posture:
- The District Attorney of Los Angeles County charged defendant Adamson in an information with murder and four counts of burglary.
- Adamson pleaded not guilty and was tried before a jury in a state trial court.
- The jury found Adamson guilty of first-degree murder, without a recommendation of mercy, and guilty of first-degree burglary.
- The trial court denied Adamson's motion for a new trial.
- An automatic appeal from the judgment on the murder count was taken to the Supreme Court of California; Adamson also appealed the burglary conviction and the denial of his new trial motion.
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 a state constitutional provision that permits a prosecutor and court to comment on a defendant's failure to testify, and allows the jury to consider that silence as tending to incriminate, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Traynor, J.
No, the state constitutional provision does not violate the Due Process Clause of the Fourteenth Amendment. The 1934 amendment to the California Constitution (Art. I, § 13) explicitly limited the privilege against self-incrimination to allow for comment on a defendant's failure to explain or deny evidence against him. Citing Twining v. New Jersey, the court held that the privilege against self-incrimination is not a fundamental right protected from state action by the Fourteenth Amendment. The court clarified that a defendant's silence does not create a presumption of guilt or relieve the prosecution of its burden to prove every element of the crime beyond a reasonable doubt. Instead, it allows the jury to infer that the evidence the defendant failed to explain is true and that among the reasonable inferences to be drawn from that evidence, those unfavorable to the defendant are more probable.
Analysis:
This case affirmed a state's right to carve out an exception to the privilege against self-incrimination, a significant departure from the federal rule and the majority of state rules at the time. It established that a defendant's silence in the face of incriminating evidence could be used as a logical link in the chain of proof, not to establish guilt directly, but to bolster the credibility of the prosecution's evidence. The decision highlighted the difficult choice faced by defendants with prior convictions, who might remain silent not because of guilt, but to prevent the jury from learning of their criminal record through impeachment. This California rule was eventually rendered unconstitutional by the U.S. Supreme Court in Griffin v. California (1965), which incorporated the Fifth Amendment's self-incrimination clause against the states.
Unlock the full brief for People v. Adamson