Estelle v. Williams, 425 U.S. 501 (1975)

Williams reinforced the concept that defendants must make timely objections; otherwise, any constitutional violations would be deemed harmless error. Williams was held in custody pending trial. On the day of trial, Williams asked for and was denied by the jail, his civilian clothes. Consequently, Williams was tried and convicted in clothes that were distinctly marked as prison clothes. Williams did not make an objection to wearing these clothes.

The Court (six to two) found that Williams’s wearing prison clothes at trial was harmless error because he did not make a timely objection. The Court held that it would violate the Fourteenth Amendment if an accused were compelled to trial in prison clothes because the jurors could be biased against him. However, the accused must make an objection in a timely manner so that the trial judge may rule on the issue. In the instant case, it was the trial judge’s practice to allow the accused to wear his civilian clothes. Because Williams had no defense to present at trial and the defense counsel referenced his prison attire at trial, it appeared that Williams wore his jailhouse clothes only to elicit jury sympathy. There was nothing in the record to show that Williams was forced to stand trial in these clothes or that there was any reason to excuse the defense from raising an objection.

Justices Marshall and Brennan dissented on the grounds that Williams’s due process rights were not waived when he did not knowingly consent to being tried in his prison clothes.

AUDREY I-WEI HUANG

References and Further Reading

• Chapman v. California, 386 U.S. 18 (1967).
• Fischer, Paul A. Annotation: Propriety and Prejudicial Effect of Compelling Accused to Wear Prison Clothing at Jury Trial—Federal Cases. American Law Reports, Federal Series 26 (2005): 535.
• Hernandez v. Beto, 443 F. 2d 634 (Fifth Cir.), cert. denied, 404 U.S. 897 (1971).
• Illinois v. Allen, 397 U.S. 337 (1970).
• Turner v. Louisiana, 379 U.S. 466 (1965).

See also Harmless Error; Substantive Due Process