Chambers v. Mississippi, 410 U.S. 284 (1973)

Unreasonable application of evidentiary principles against a criminal defendant may violate the U.S. Constitution on any number of grounds, including the Compulsory Process, Due Process, or Confrontation Clauses. Chambers v. Mississippi, 410 U.S. 284 (1973), stands for the proposition that the Due Process right to a fair trial is implicated when evidentiary rules deprive a criminal defendant of the right to present evidence critical to his defense.

Chambers involved the shooting of a police officer during a fracas in a Mississippi pool hall. While some evidence pointed to Leon Chambers as the perpetrator, another man—Gable McDonald—later confessed to the crime. McDonald, however, recanted one month after his confession. Unable to inquire fully into the nature of McDonald’s confession and recantation on cross-examination at trial due to state evidence rules, Chambers’ defense team sought to introduce the testimony of three witnesses to whom McDonald had admitted participation in the shooting. Nevertheless, McDonald’s statements to these witnesses were deemed inadmissible hearsay under state law, and Chambers was convicted of murder. In an 8–1 decision, the U. S. Supreme Court reversed Chambers’ conviction, finding that state law prevented him from developing his defense and thereby interfered with hisDue Process rights.

Although the Supreme Court opinion was crafted narrowly and linked to the facts of the case, Chambers has subsequently taken on significance as a landmark case for criminal defendants: a bulwark safeguarding a defendant’s right to present exculpatory evidence in his own defense.

DANIEL S. MEDWED

References and Further Reading

• Fisher, George. Evidence (2002): 580–586
• Hoeffel, Janet C., The Sixth Amendment’s Lost Clause: Unearthing Compulsory Process, Wis. L. Rev. (2002): 1275
• Nagareda, Richard A., Reconceiving the Right to Present Witnesses, 97 Mich. L. Rev. 1999: 1063

Cases and Statutes Cited

• In re Oliver, 333 U.S. 257 (1948) 
• Webb v. Texas, 409 U.S. 95 (1972) 
• Washington v. Texas, 388 U.S. 14 (1967) 

See also Confrontation and Compulsory Process; Defense, Right to Present; Due Process