Rochin v. California

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Following is the case brief for Rochin v. California, Supreme Court of the United States, (1925)

Case Summary for Rochin v. California:

  • While searching Rochin’s home, officers asked what was in the capsules found by his nightstand. Rochin responded by swallowing the capsules.
  • Officers arrested Rochin and had his stomach pumped against his will, yielding two pills which contained morphine.
  • Rochin was convicted of possessing narcotics and appealed his conviction, claiming it violated his Due Process rights.
  • The Court held that forced extraction of bodily contents shocks the conscious, and as a result, violates the 14th Amendment’s Due Process clause.

Case Brief for Rochin v. California

Statement of the facts:

Based off “some information”that Rochin was selling narcotics”, police searched Rochin’s home, forcing their way into his bedroom. When the officers asked what was in the two capsules located on his nightstand, Rochin grabbed the pills and swallowed them. Rochin was then immediately arrested and taken to the hospital where the police ordered the doctor’s to pump Rochin’s stomach against his will. This caused Rochin to vomit, expelling the capsules from his stomach. It was later determined that the pills contained Morphine. This evidence was admitted at trial and Rochin was convicted of possessing morphine.

Procedural History:

Morphine appealed his conviction. The Supreme Court granted certiorari.

Rule of Law or Legal Principle Applied:

Officers cannot procure physical evidence through forcible extraction of stomach contents.

Issue and Holding:

Can an officer obtain physical evidence through forceful extraction of the defendant’s stomach contents? No.

Judgment:

The Court held that the forced extraction was improper and reversed the lower court’s decision.

Reasoning:

Officers cannot obtain physical evidence through forcible extraction by pumping a defendant’s stomach content. The Court held that this type of conduct shocks the conscious, violating the 14th Amendment’s Due Process clause. Here, pumping Rochin’s stomach absent his own permission, violates his rights under Due Process. The Court also compares the forced pumping to a coerced confession. Holding that officers “cannot extract by force what is in a defendant’s mind but can extract what is in his stomach” would be inconsistent and improper. As a result, forced withdrawal through stomach pumping was improper.

Concurring or Dissenting opinion:

Concurring (Douglas):

The Fifth Amendment right against self-incrimination applies to physical evidence taken absent consent, such as blood and the contents pumped from Rochin’s stomach.

Concurring (Black):

The Fifth Amendment right against compelled self-incrimination applies in this case.

Significance:

This case helped shed light on the concept that obtaining evidence or a confessions by beating or torture were specific methods the right against self-incrimination was meant to prevent.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/342/165
https://supreme.justia.com/cases/federal/us/342/165/case.html