Rideau v. Louisiana
373 U.S. 723 (1963)
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Rule of Law:
The denial of a defendant's request for a change of venue, in a community pervasively exposed to a televised spectacle of the defendant's detailed in-jail confession, constitutes a violation of the Due Process Clause of the Fourteenth Amendment. Under such circumstances, prejudice is presumed, and a particularized showing of juror bias is not required.
Facts:
- On February 16, 1961, a man robbed a bank, kidnapped three bank employees, and killed one of them in Lake Charles, Louisiana.
- A few hours later, police apprehended Wilbert Rideau and detained him in the Calcasieu Parish jail.
- The next morning, the Sheriff of Calcasieu Parish conducted a 20-minute filmed "interview" with Rideau in the jail.
- During this interview, Rideau, in response to the sheriff's leading questions, admitted in detail to committing the bank robbery, kidnapping, and murder.
- This filmed confession was broadcast on a local television station on three separate days to audiences estimated at 24,000, 53,000, and 29,000 people.
- The total population of Calcasieu Parish was approximately 150,000 people.
Procedural Posture:
- Wilbert Rideau was arraigned in Calcasieu Parish trial court on charges of armed robbery, kidnapping, and murder.
- His appointed lawyers filed a motion for a change of venue, arguing the televised confession made a fair trial in the parish impossible.
- The trial court judge denied the motion for a change of venue after a hearing.
- During jury selection, the trial judge denied challenges for cause against three jurors who had seen the confession and two jurors who were deputy sheriffs, after the defense had exhausted its peremptory challenges.
- Rideau was convicted of murder by the jury and sentenced to death.
- Rideau appealed to the Supreme Court of Louisiana, which affirmed the conviction and sentence.
- The United States Supreme Court granted Rideau's petition for a writ of certiorari.
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Issue:
Does refusing a defendant's request for a change of venue, after his detailed in-jail confession was televised three times to a large portion of the community, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Justice Stewart
Yes, refusing the request for a change of venue was a denial of due process of law. When a community has been repeatedly and in-depth exposed to the spectacle of a defendant personally confessing to the crimes, any subsequent court proceedings in that community are but a hollow formality. The televised event was, in a very real sense, Rideau's trial, at which he pleaded guilty before tens of thousands of viewers. The Court held that due process required a trial before a jury drawn from a community that had not been exposed to this inherently prejudicial spectacle, making it unnecessary to examine the voir dire record for specific evidence of juror bias.
Dissenting - Mr. Justice Clark
No, the denial of the motion for a change of venue did not violate due process. The majority fails to establish a substantial nexus between the televised interview and the trial, which occurred almost two months later. The burden is on the petitioner to show essential unfairness, and he failed to do so. Only three of the twelve seated jurors had seen the interview, and they all testified that they could lay aside any opinion and be impartial. Unlike cases such as Irvin v. Dowd, there was no showing of a deep and bitter prejudice permeating the community that fatally infected the trial.
Analysis:
This case is significant for establishing the doctrine of presumed prejudice in the context of pre-trial publicity. The Court departed from the traditional standard, which required a defendant to show actual prejudice among the seated jurors. By holding that certain types of publicity are so inflammatory and pervasive that prejudice can be assumed, the decision provided a crucial safeguard for defendants' due process rights in high-profile cases. This precedent allows courts to mandate a change of venue based on the nature of the publicity itself, without a difficult and often fruitless inquiry into the jurors' states of mind.
