Case Comparison of Adamson V California

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Table of Contents

Adamson v California, 332 U.S. 46 (1947)
Griffin v California, 380 U.S. 609 (1965)
Ebscobedo v Illinois, 378 U.S. 478 (1964)
Conclusion
References

The U.S. constitution provides for certain fundamental rights in its provisions. Key among these are the fourth, fifth, sixth and eighth amendment’s, which provide for the rights of American citizens. The fourth amendment provides for searches and seizures, providing respite in cases where they are ‘unreasonable’. It also pConstitutionunlawfully obtained evidence by outlining the exclusionary rule. The Fifth Amendment prohibits the admission of self-incriminating statements as well as those in the form of confessions that are a result of coercive interrogations (Beckerly 169). The law seems to overlap at this point because these statements, just like the evidence collected unlawfully are inadmissible in a court of law. The sixth amendment provides for the right to an attorney as well as juvenile rights, and finally, the eighth amendment caters for cruel and unusual punishments or simply put, the proportionality of sentencing to a crime. Most of these rights tend to overlap as they are closely related. However, the law is very strict on the infringement of any of them as in most cases; it renders the sentence and the entire trial null.

Adamson v California, 332 U.S. 46 (1947)

Facts: the defendant, Adamson was convicted of first degree murdered and given a death penalty. He appealed his conviction on the grounds that the law in California that allowed the prosecution and the court (judge) to comment on his failure to provide a testimony violated the Fifth Amendment, which prohibited forced self incrimination. This comment rule allowed the judge to direct the jury to infer guilt from the defendant’s lack of testimony to either rebut or explain the evidence and it was a violation of the right of presumption of innocence. The Supreme Court upheld the conviction.

Issue: the question raised was whether the Fifth Amendment provision against compelled self incrimination should be applied in states as it was in the federal circuit because of the due process clause in the 14^th amendment.

Holding: No

Reasoning: the freedom to either give or not give a testimony in court was not a fundamental right provided for in the Bill of Rights. Although all American citizens had the right to a fair trial, the freedom from compelled testimony was not inherently incorporated in this right.

Significance: This reasoning was flawed because it expressly denied a defendant his right to a presumption of innocence. It meant that a defendant could not enjoy his right to silence, yet this is a critical right in criminal proceedings (Osbourne 19). Consequently, such a defendant is “damned if he does and damned if he doesn’t.” This especially applies where the defendant may get flustered if he testifies and the jury may infer guilt if he does not.

Griffin v California, 380 U.S. 609 (1965)

Facts: the defendant was convicted of murder and given a death penalty after a witness testified to having seen him with the victim, Essie Mae, in an alley, and him later emerging from the alley alone. During trial, the defendant failed to testify as advised by his counsel, and the prosecution commented extensively on his silence. The judge also directed the jury to infer the truth of the prosecution’s evidence from his lack of a testimony to either rebut or explain the evidence. The defendant appealed.

Issue: whether the state’s (California) law allowing the comment rule was a violation of the defendant’s constitutional right as provided for by the Fifth Amendment and as applied in the federal circuit.

Holding: Yes

Reasoning: the comment rule denied the defendant’s right to a presumption of innocence. Moreover, it was in contravention of the Fifth Amendment provision which prohibited forced self-incrimination. Finally, it was ludicrous to apply different standards in the state and federal levels as initially established in Malloy v Hogan [1964]. Therefore, if it was unconstitutional to allow a court to comment on the silence of a defendant in the federal circuit, it was also unconstitutional at state level.

Significance: This case ensured the preservation of the presumption of innocence, which is a constitutional right (Serea, & Finn 87). It also made it clear that commenting on a defendant’s silence is a contravention of his / her Fifth Amendment rights and therefore a violation of the due process requirement.

Ebscobedo v Illinois, 378 U.S. 478 (1964)

Facts: the defendant was a 22-year old Mexican arrested with his sister as suspects for the murder of his brother-in-law. The murder occurred at a fatal shooting some 11 days before and the defendant had been arrested earlier for interrogation. He had not made a statement and was released after his lawyer made a petition for a habeas corpus. On the second arrest, he was denied access to his attorney, although the attorney was in the same building also trying to gain access to his client, and after some coercive interrogation, he gave a statement to an assistant prosecutor that was self-incriminating in its contents. The police had not informed him on his right to remain silent. The defendant appealed.

Issue: whether the rights of the accused had been violated according to the fifth and sixth amendments which provided for his right to an attorney and from self incrimination. This question was in view of the defendant being an actual suspect whom the police had narrowed down onto and whether the court should exclude as evidence his statements made in the absence of an attorney.

Holding: Yes, appeal allowed

Reasoning: although the accused was already a suspect, he needed to know of his right to silence and needed access to his attorney to advise him on how to answer the questions that the police were directing at him, and none of these rights were observed.

Significance: The infringement of a defendant’s fundamental rights disqualifies any validity of the case against them. It does not matter how convincing the evidence against them appears (Wyatt, & Simpson 39). Therefore, in the administration of justice, it is critical that the prosecution, law enforcement officers, the judge, the jury, and all other concerned parties adhere to the constitutional requirements of the due process.

Conclusion

From the three cases, it is evident that the provisions of the fourth, fifth, sixth, and eighth amendment’s sometimes overlap within a single case, as they did in Ebscobedo v Illinois. However, even when they do, they are still treated individually as independent violations of fundamental rights.

References

Beckerly, Thomson. Constitutional Law: Cases and Materials. Chicago: Oxford University Press, 2006.

Osbourne, Jerry. “Searches and Seizures.” Legal Brief Monthly (2008): 14-32.

Serea, Vera & Finn,Kennington. Constitutional Rights: The 4th, 5th, 6th, and 8th Amendments. New York: Adventure Works Press, 2009.

Wyatt, Davis, & Simpson, Layton. “The Eighth Amendment: Proportionate Sentencing.” Havard Law Review (2009): 34-56.

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