Today marks the 78th anniversary of the landmark Supreme Court case of Chambers v. Florida. Chambers stands for the proposition that confession obtained through non-physical coercion must be suppressed.
Unfortunately, the case behind Chambers was far to common for African-Americans in the South. On May 13th, 1933 Robert Darsey, an elderly white man was robbed and murdered in Pompano Beach, Florida. Shortly after Darsey’s death, a mob of hundreds of white people began rioting. Police arrested 40 African-Americans without warrants, and held them in Broward County jail regarding Darsey’s murder. Over the following six days, 40 men were separated and interrogated at all hours of the day and night, sometimes by as many as 10 police officers at a time. The men were further separated and transported to Fort Lauderdale Florida, ostensibly for their own safety. At no point during these interrogations was anyone told about their right to remain silent or allowed to speak with their family or lawyer.
After a week, the police had narrowed their focus on four men, Isiah Chambers, Jack Williamson, Charlie Davis and Walter Woodward. Following a 12 hours interrogation the first man broke Walter Woodward confessed to the murder. In the following 12 hours, the other three men also broke each confessing to the murder. The District Attorney continually rejected their confessions until all of their confessions matched. The four where then brought to trial each charged with capital murder. The means defense attorneys sought to suppress the confessions arguing they had been obtained by duress. Unfortunately, the judge rejected their motion, the jury found their confessions to be voluntary, found them guilty based on the confessions alone, and the four were sentenced to death. The four appealed their convictions on the grounds that their confessions should have been suppressed. The Florida Court of Appeals and the Florida Supreme Court affirmed their convictions noting that confessions obtained through duress did not violate due process, only through physical violence. The four men then sought a writ of certiorari from the Supreme Court and were granted cert in late 1939.
The Supreme Court heard arguments January 4th of 1940. The four co-defendants represented by Thurgood Marshall argued that the due process clause of the 14th amendment required that confessions obtained through duress be suppressed. They argued that the threat of mob violence, the isolation, and the extended interrogations overcame the defendants free will.
The State argued that the officers had not physically assaulted the men to obtain the confessions, and as such their confessions where voluntary. The State also argued that if the Supreme Court found this method of interrogation unconstitutional, it would hammer police ability to achieve justice.
The Supreme Court rendered its judgment on February 12th, 1940. The Court, in a unanimous decision led by Justice Hugo Black held that the four men’s 14th amendment right to due process had been violated when the State of Florida allowed the confessions obtained through duress to be entered into evidence. Hugo Black, in the blister opinion stated:
“Today, as in ages past, we are not without tragic proof that the exalted power of some governments to punish manufactured crime dictatorially is the handmaid of tyranny. Under our constitutional system, courts stand against any winds that blow as havens of refuge for those who might otherwise suffer because they are helpless, weak, outnumbered, or because they are nonconforming victims of prejudice and public excitement. Due process of law, preserved for all by our Constitution, commands that no such practice as that disclosed by this record shall send any accused to his death. No higher duty, no more solemn responsibility, rests upon this Court than that of translating into living law and maintaining this constitutional shield deliberately planned and inscribed for the benefit of every human being subject to our Constitution–of whatever race, creed or persuasion.”
Interestingly, Justice Frank Murphy specially stated he had no part of the deliberation of this case, not wanting to have his name attached to the decision.
With the Court’s judgment rendered, the four men had their convictions overturned and remanded for a new trial. In a peculiar twist, the four men never stood trial again as after the decision but before the new trial the four men “escaped” from Broward County jail and where never recaptured. This opinion was also interesting because Justice Hugo Black wrote the opinion. Justice Black, at one time before he got involved in politics was a member of the Ku Klux Klan. However, After Justice Black became a Supreme Court Justice, he penned most of the courts pro civil rights, and pro criminal justice reform opinions which all had profoundly positive effects of African-Americans. Justice Felix Frankfurter would later note that this opinion was “one of the enduring utterances in the history of the Supreme Court and in the annals of human freedom,”.
This decision was the first time the Supreme Court recognized that non-violent coercion can overcome a person free will and make them confess to something they did not do. This case stands for the simple proposition that confessions compelled by police through duress are inadmissible at trial. With Experienced Legal Representation, you can ensure that coerced confessions are not used against you.
Written By Hunter J. White
 Chambers v. Florida, 309 U.S. 227, 60 S. Ct. 472 (1940)