Sheppard v. Maxwell

Following is the case brief for Sheppard v. Maxwell, 384 U.S. 333 (1966)

Case Summary of Sheppard v. Maxwell:

  • Sheppard was accused of killing his pregnant wife.
  • He maintained his innocence, but the case became very highly publicized, clearly characterizing Sheppard as the killer.
  • The publicity was so intense, in fact, that numerous incriminating stories were written about it, and the press essentially took over most of the courtroom and courthouse during the trial.
  • Sheppard was convicted of second-degree murder.  After exhausting all of his direct appeals, he filed a habeas corpus petition in federal court claiming that he was denied a fair trial.
  • The District Court agreed with Sheppard, but the Sixth Circuit reversed.
  • The U.S. Supreme Court reversed the Sixth Circuit, finding that the publicity and “bedlam” around the trial was so prejudicial that it constituted a denial of due process under the Fourteenth Amendment.

Sheppard v. Maxwell Case Brief

Statement of the Facts:

Dr. Sam Sheppard’s pregnant wife was bludgeoned to death one evening, and Sheppard became the prime suspect.  Sheppard maintained his innocence throughout the trial.

It is fair to say that the trial of Sheppard was utter chaos.  The following paints a picture of how the proceedings were handled in the highly publicized case:

  • The case became notorious due to virulent and incriminating publicity.
  • Three months prior to trial, Sheppard was examined for more than five hours without counsel in a televised three-day inquiry, done before an audience of hundreds of spectators at a gymnasium.
  • The names and addresses of the trial jurors were published by the press.
  • The trial began two weeks before an election, in which the trial judge and the chief prosecutor were candidates for judgeships.
  • Journalists were permitted to take over almost the entire courtroom, and the courthouse.
  • Reporters were seated very close to the jury and counsel.
  • A broadcasting station was placed in a room next to the jury room.
  • The jurors were not sequestered before deliberations and had access to all media about the case. Even during deliberations, the jurors’ phone calls were not adequately supervised.
  • Much of the press coverage involved incriminating information that was not produced at trial.
  • The jurors were thrust into the roles of celebrities.
  • The trial judge, claiming he could not control the press, did nothing to control the prejudicial news accounts.

Sheppard was ultimately found guilty of second-degree murder.  He exhausted all of his direct appeals.

Procedural History:

  • Sheppard filed a habeas corpus petition, claiming that he was denied a fair trial given the massive, pervasive, and prejudicial publicity surrounding his trial.
  • The District Court agreed that Sheppard did not receive a fair trial.
  • The Sixth Circuit Court of Appeals reversed.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Can massive, pervasive, and prejudicial publicity, and a carnival-like atmosphere in the courtroom, deprive a defendant of a fair trial?  Yes.

Judgment:

The decision of the Sixth Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

When pre-trial and trial publicity is so intense and prejudicial that it is probable that prejudice will result, then there is a violation of due process under the Fourteenth Amendment.

Reasoning:

The Court noted the many, many examples of prejudicial, inflammatory publicity surrounding the case, and found that “bedlam reigned at the courthouse during the trial, and newsmen took over practically the entire courtroom.”  Thus, the Court reasoned that the totality of the circumstances demonstrated that Sheppard was not given a fair trial.  The “carnival atmosphere” was such that it prejudiced the trial to the point of being a deprivation of due process in violation of the Fourteenth Amendment.

Further, the trial court compounded the problem by acting as if it was powerless to control the trial publicity.  The court could have controlled the proceedings by (i) limiting the number of reporters, (ii) insulating the witnesses, and (iii) making some effort to control the release of information and gossip.

Concurring & Dissenting Opinions:

Justice Black dissented from the judgment without opinion.

Significance:

Sheppard v. Maxwell is significant because it presented a situation where, essentially, the First Amendment clashed with the rights to a fair trial and due process.  The Court in this case, while trying to honor the press’ First Amendment rights, identified the threshold point when the press freedom infringes on due process fairness.  The “bedlam”-like atmosphere at Sheppard’s trial was found to go too far for due process purposes.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

 

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