Adamson v. California

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Following is the case brief for Adamson v. California, Supreme Court of the United States, (1947)

Case summary for Adamson v. California:

  • Adamson was charged with first degree murder. At trial, he failed to deny the evidence offered against him and the judge instructed the jury that such failure can be used as evidence of guilt.
  • Adamson was convicted and appealed claiming that the instruction violated the Due Process Clause of the 14th Amendment.
  • The Court held that the 14th Amendment’s Due Process Clause is not violated if a jury is permitted to infer a defendant’s guilt after he fails to deny the evidence entered against him.

Adamson v. California Case Brief

Statement of the facts:

While on trial for first degree murder, Adamson failed to testify in regards to the evidence admitted against him. In a jury instruction, the judge informed the jury that it could infer guilt based on Adamson’s failure to deny the evidence. Adamson was convicted and in response, brought a claim challenging the constitutionality of the state law.

Procedural History:

Adamson appealed his conviction up to the state supreme court, which affirmed the trial court’s judgment. In response, Adamson appealed to the Supreme Court of the United States.

Rule of Law or Legal Principle Applied:

The 14th Amendment’s Due Process Clause is not violated when a jury is permitted to infer a defendant’s guilt, when he fails to deny the evidence entered against him.

Issue and Holding:

Whether instructing a jury to infer a defendant’s guilt from their failure to deny the evidence offered against them is unconstitutional under the 14th Amendment’s Due Process Clause? No.

Judgment:

The Court affirmed the lower court’s judgment.

Reasoning:

The Court held that although the Due Process Clause does guarantee the right to a fair trial, that does not mean that the clause incorporates all the protections of the Bill of Rights to the individual states. The provisions of the Bill of Rights deemed as “implicit in the concept of ordered liberty” are protected by the Due Process Clause. It is true that the 14th Amendment protects individuals from unfair convictions, but that does not mean that it is fundamentally unfair to permit a jury to make an inference based on the defendant’s failure to deny the evidence offered against him.

Concurring or Dissenting opinion:

Concurring (Frankfurter):

The central issue in determining whether the 14th Amendment incorporates a specific right is whether the proceedings in question are under accepted notions of justice, not whether the Bill of Rights protects the right.

Dissenting (Black):

History makes it evident that the intent behind the 14th Amendment was to apply the Bill of Rights to the individual states.

Dissenting (Murphy):

The Bill of Rights should apply to the states through the 14th Amendment, but the scope of included protections is not solely limited to the Bill of Rights. Situations where a proceeding violates due process should not be overlooked just because they are not violations referenced in the Bill of Rights.

Significance:

This case points out that the Bill of Rights is incorporated to the states through the 14th Amendment.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/332/46
https://supreme.justia.com/cases/federal/us/332/46/case.html