Today marks the 71st anniversary of the devastating Supreme Court case of Adamson v. California. Adamson upheld the Supreme Court’s previous ruling in Twining which denied the 5th amendment protections against self-incrimination in state trials.
The case behind Adamson is shocking to say the least. On July 25th, 1944, an apartment manager in Los Angelis was called to open the door of a tenant who had not been seen for a day. When the manger opened the door, he found the body of Ms. Stella Blauvelt, a red cross nurse and widower. Ms. Blauvelt had been strangled to death and her apartment robbed. Days later police would arrest Admiral Dewey Adamson, an African-American man and charge him with 1st degree murder. At trial, the State offered fingerprints from near the crime scene that matched Mr. Adamson and one witness who testified she had overheard him trying to sell some of the stolen goods from the apartment. Mr. Adamson had two prior convictions for burglary and robbery. Because of these prior convictions, the risk of impeachment, and the general rule that you never testify on your own behalf, Mr. Adamson did not take the stand in his own defense at trial. Mr. Adamson also did not present any witnesses for his defense.
In closing statements, the prosecutor railed on the point that Mr. Adamson had not testified, and rapidly raised the point that California law allowed for the jury to make an adverse finding from a defendant’s failure to testify on their own behalf. The California constitution was one of a few state constitutions at that time which did not have its own guarantee of the right against self-incrimination. The jury found Mr. Adamson guilty and the judge sentenced him to death. Mr. Adamson appealed his case to the California Appellant Courts, and the California Supreme Court who unanimously affirmed his conviction based on the case of Twining in 1946 In late 1946 with his death date approaching Mr. Adamson sought a writ of certiorari from the Supreme Court on the issue of self-incrimination and was granted cert in late 1946.
The Supreme Court heard arguments on January 15th and 16th 1947. Mr. Adamson argued that the California law which allowed the jury to make an adverse inference from him exercising his 5th amendment right to silence effective violated that right. Mr. Adamson argued that the Court should incorporate the 5th amendment against the states as is had with other rights at this point.
The State argued that precedent held that the Supreme Court should not overturn Twining, and that the Defendant’s 5th amendment right may have been violated by the law, but the weight of the evidence was the primary factor the jury used to determine his guilt.
On June 23rd, 1947, the Supreme Court rendered its judgment. In a 5 – 4 decision, the majority led by Justice Stanley F. Reed held that the 5th amendment did not apply to state trials, thus upholding Twinning. This effectively affirmed Mr. Adamson’s conviction.
Justice Felix Frankfurter wrote his own separate concurrence, argued that none of the Constitutional rights should be incorporated against the states and the Supreme Court should reject the selective incorporation doctrine.
Justice Hugo Black wrote a length dissent joined by Justice William O. Douglas in which he argued that the Supreme Court should incorporate all 8 amendments of the Constitution against the states and be done with the process of selective incorporation.
Justice Frank Murphy also wrote a dissent joined by Justice Wiley B. Rutledge which followed Justice Black’s line of thinking, but also sought for the Supreme Court to incorporate rights not enumerate in the Constitution against the states as well.
With his appeals exhausted, Mr. Adamson was put to death by gas on December 9th, 1949. While this case would eventually be overturned by Malloy v. Hogan, this case stands as a testament to the slow gears of justice at work in the Supreme Court. With Experienced Legal Representation, you can protect yourself from having your Constitutional rights violated.
Written By Hunter White
 Adamson v. California, 332 U.S. 46, 67 S. Ct. 1672 (1947)
 Twining v. New Jersey, 211 U.S. 78, 29 S. Ct. 14 (1908)
 Malloy v. Hogan, 378 U.S. 1, 84 S. Ct. 1489 (1964)