Criminal Procedure Test 5 - Specific Court Cases

Wayte v. United States - What was the holding?

Holding: Prosecutors retain “broad discretion” as to whether to prosecute, and there is a presumption of regularity. To challenge selective prosecution, defendant must demonstrate both: (1) discriminatory effect - that similarly situated individuals were treated differently; AND (2) discriminatory purpose - that the policy was motivated by intent to discriminate

Blackledge v. Perry - What was the holding?

Holding: An individual convicted of an offense is “entitled to pursue his statutory right to a trial de novo without apprehension that the State will retaliate by substituting a more serious charge for the original one” This established protection against vindictive prosecution

United States v. Goodwin - What was the holding?

Holding: Prosecutors have many legitimate reasons for changing charges against an individual, and changes cannot automatically be assumed to be vindictive. This limits claims of vindictive prosecution by requiring evidence of actual vindictiveness

Gerstein v. Pugh - What was the holding?

Holding: Following an arrest without a warrant or grand jury indictment, the government must provide a prompt judicial determination of probable cause to detain the suspect for an extended period (Gerstein hearing)

County of Riverside v. McLaughlin - What was the holding?

Holding: Defined “promptly” in Gerstein - probable cause hearings must generally be held within 48 hours of arrest. Delays beyond 48 hours are presumptively unreasonable unless justified

Schlib v. Kuebel - What was the holding?

Holding: Recognized the constitutional right to bail as provided by the Eighth Amendment

Stack v. Boyle - What was the holding?

Holding: The court declared that the primary purpose of bail is to ensure that the defendant appears for trial. Bail must not be excessive - it should be no more than necessary to accomplish this purpose

Carlson v. Landon - What was the holding

Holding: Addressed the Bail Clause and clarified that bail is not an absolute right in all circumstances, particularly in cases involving deportation or national security

Bell v. Wolfish - What was the holding?

Holding: While pretrial detainees retain their constitutional rights, they are subject to reasonable regulations intended to ensure order and security in the institution. These detainees have not been convicted of a crime and may not be subjected to “arbitrary or purposeless’ conditions that constitute punishment.

Powell v. Alabama - What was the holding?

Holding: Established a limited right to appointed counsel for indigents who were “incapable” of representing themselves and who were facing the death penalty. This was the first major Supreme Court case addressing right to counsel (1932).

Gideon v. Wainwright - What was the holding?

Holding: The right to counsel is fundamental and essential to a fair trial. States must provide counsel to indigent defendants in felony cases. Extended Powell to all felonies, not just capital cases (1963).

Argersinger v. Hamlin - What was the holding?

Holding: "Absent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless he was represented by counsel.” Extended right to counsel to misdemeanors where imprisonment is imposed (1972).

Scott v. Illinois - What was the holding?

Holding: “No indigent criminal defendant [is to] be sentenced to a term of imprisonment unless the State has afforded him the right to assistance of appointed counsel in his defense.” The right to counsel does not apply if the defendant is only subjected to a fine. Unless provided with a lawyer, a judge may not sentence a defendant to imprisonment (1979).

Kirby v. Illinois - What was the holding?

Holding: Established the two-part test for when Sixth Amendment right to counsel attaches: (1) adversarial judicial proceedings must have been initiated (by formal charge, preliminary hearing, indictment, information, or arraignment); AND (2) the proceeding must be a “critical stage” that may negatively impact defendant’s ability to present a defense

Morris v. Slappy - What was the holding?

Holding: There is no constitutional right to a “meaningful attorney-client relationship.” A defendant has no right to be represented by a specific appointed counsel. A court cannot guarantee that an attorney and client share a close working relationship or that the defendant has trust and confidence in their assigned attorney.

Strickland v. Washington - What was the holding and test?

Holding: Established the two-pronged test for ineffective assistance of counsel: (1) Deficient Performance - counsel’s performance fell below objective standard of reasonableness (presumption of adequate counsel; totality of circumstances); AND (2) Prejudice - reasonable probability that, but for counsel’s errors, the result would have been different. Defense attorney has “overarching duty to advocate the defendant’s cause” and to “bring to bear such skill and knowledge as will render the trial a reliable adversarial testing process.”

Faretta v. California - What was the holding?

Holding: A defendant has a constitutional right to self-representation (to proceed pro se). A refusal to permit a defendant to represent himself or herself will result in reversal on appeal of the verdict in the trial court. However, this right is subject to limitations (notice, competence, non-disruptiveness).

McKaskle v. Wiggins - What was the holding?

Upheld the practice of appointing “standby counsel” to assist a defendant with his or her defense, even when the defendant is representing themselves. The standby counsel can provide assistance without undermining the defendant’s right to self-representation

Martinez v. Court Appeal of California - What was the holding?

Holding: There is no constitutional right to self-representation on appeal. The right established in Faretta applies only to trial,, not appellate proceedings

Hurtado v. California - What was the holding?

Holding: States are NOT required to provide grand jury indictment under the Fifth Amendment - this right has not been incorporated against the states through the Fourteenth Amendment. States may use other charging mechanisms like preliminary hearings and informations

Vasquez v. Hillery - What was the holding?

Holding: Established the automatic reversal rule - discrimination in the selection of grand jurors requires automatic reversal of any conviction, regardless of the strength of the evidence. This enforces Equal Protection requirements strictly in grand jury selection

United States v. Disfrancesco - What was addressed?

Addressed the scope and application of the Fifth Amendment Double Jeopardy Clause, clarifying that an individual may not be prosecuted more than once for the same offense or punished more than once for the same crime

Klopfer v. North Carolina - What was the holding?

Holding: The right to a speedy trial is “one of the basic rights preserved by our Constitution” and is fundamental. This case incorporated the Sixth Amendment speedy trial right against the states

Groppi v. Wisconsin - What was the holding?

Holding: A state is required to allow a change of venue in those instances in which a defendant demonstrates that a fair trial cannot be achieved in the original district due to prejudice or publicity

Brady v. Maryland - What was the holding?

Holding: Established the Brady rule - the prosecution must disclose exculpatory evidence (evidence favorable to the defendant) to the defense. The purpose is to prevent miscarriages of justice by requiring disclosure of evidence that may prevent conviction of an innocent individual or result in reduction of sentence. Violation of Brady Rule can result in reversal of conviction.

Duncan v. Louisiana - What was the holding?

Holding: Incorporated the Sixth Amendment right to jury trial against the states through the Fourteenth Amendment. The right to jury trial is fundamental in cases involving serious crimes

Baldwin v. New York - What was the holding?

Holding: Established that the right to jury trial attaches to crimes punishable by more than 6 months imprisonment. This defines the dividing line between “petty” offenses (no jury right) and “serious” offenses (jury right required).

Coddispoti v. Pennsylvania - What was addressed?

Addressed the right to jury trial in the context of criminal contempt proceedings, applying the principles from Baldwin v. New York

Blanton v. City of North Las Vegas - What was addressed?

Further defined when jury trial rights attach, examining whether offenses should be classified as “petty” or “serious” based on potential punishment and other factors

Lewis v. United States - What was the holding?

Holding: Addressed whether multiple petty offenses, when combined can trigger the right to jury trial. Generally held that the nature of individual offenses, not aggregate potential penalty, determines jury trial right

Thompson v. Utah - What was the holding?

Holding: The Sixth Amendment follows common law and guarantees an individual a jury composed of 12 persons, “neither more nor less” in federal court. This established the federal standard.

Williams v. Florida - What was the holding?

Holding: States are NOT required to use 12-member juries under the Sixth Amendment. Six-person juries are constitutionally permissible in state court

Ballew v. Georgia - What was the holding?

Holding: Five jurors is too few - this violates the Sixth Amendment. Six jurors is the constitutional minimum. Below six, the jury becomes too small to fulfill its functions of community representation and group deliberation

Norris v. Alabama - What was the holding?

Holding: Established the “rule of exclusion” - the systematic exclusion of African Americans from jury service violates the Equal Protection Clause. This case was part of the Scottsboro Boys litigation and addressed racial discrimination in jury selection

Glasser v. United States (1942) - What was the holding?

Holding: The Sixth Amendment requires that a federal jury be drawn from a fair cross section of the community in which the crime as been committed. This ensures: (1) better decision-making; (2) impartial jury; (3) fairness to defendants; (4) protection of civil rights

Ham v. South Carolina (1973) - What was the holding?

Holding: The most important Supreme Court case regarding racial prejudice and voir dire. Trial court must allow questioning about racial prejudice when race is a central issue in the case. This ensures an impartial jury under the Sixth Amendment.

Swain v. Alabama - What was the holding?

Holding: Peremptory challenges are “fundamental to a fair trial” and “one of the most important of the rights secured to the accused. “However, this case made it very difficult to prove racial discrimination in peremptory challenges (later modified by Batson).

Batson v. Kentucky - What was the holding?

Holding: The Equal Protection Clause prohibits prosecutors from using peremptory challenges to exclude jurors based solely on race. Established a three-step process: (1) defendant makes prima facie showing of discrimination; (2) prosecution must provide race-neutral explanation; (3) court determines if discrimination occurred. This overruled the restrictive standard in Swain.

Caperton v. A.T. Massey - What was the holding?

Holding: Due Process requires judicial recusal when there is a serious, objective risk of actual bias, such as when a litigant contributed significant campaign funds to a judge’s election. Established standards for when conflicts of interest require judges to step aside.

Williams v. Pennsylvania - What was the holding?

Holding: Due process requires recusal when a judge had significant prior involvement with the case in another capacity (e.g., as prosecutor), creating appearance of bias or actual bias in the proceeding

What cases address when proceedings may be closed to the public?

Courts have held that: (1) Press and public may be excluded from preliminary hearing where there is substantial probability that publicity will prejudice defendant’s right to fair trial and there are no reasonable alternatives; (2) Proceedings may be closed to protect juveniles alleged to be victims of sexual abuse. Public trial right must be balanced against other compelling interests

Davis v. Alaska - What was the holding?

Holding: The Confrontation Clause guarantees the right to effective cross-examination, including the right to impeach witnesses and expose biases, motives, or credibility issues. State interest in protecting juvenile records must yield to defendant’s right to confrontation

Olden v. Kentucky - What was the holding?

Holding: Further established that limits on cross-examination that prevent a defendant from presenting a complete defense or exposing witness bias violate the Confrontation Clause. Defendant must be allowed reasonable cross-examination on relevant matters.

Ohio v. Roberts - What was the holding?

Holding: Established the “reliability” test for hearsay under the Confrontation Clause - hearsay is admissible if it has adequate “indicia of reliability,” either by falling within a firmly rooted exception or showing particularized guarantees of trustworthiness. (Later modified by Crawford)

Crawford v. Washington - What was the holding?

Holding: Overruled Ohio v. Roberts. The Confrontation Clause bars admission of “testimonial” statements made outside of court unless: (1) the witness is unavailable; AND (2) the defendant had a prior opportunity to cross-examine the witness. Reliability is not enough - cross-examination is required for testimonial statements

Davis v. Washington - What was the holding?

Holding: Distinguished between testimonial and non-testimonial statements for Confrontation Clause purposes. Statements made during ongoing emergency to police for assistance are non-testimonial; statements given to establish past facts for prosecution are testimonial. Only testimonial statements trigger Confrontation Clause protections

Michigan v. Bryant - What was the holding?

Holding: Further refined the testimonial/non-testimonial distinction from Davis. Statements made to police during an ongoing emergency, even if victim is dying, may be non-testimonial if primary purpose is to address the emergency rather than establish facts for prosecution.

Ohio v. Clark - What was the holding?

Holding: Statements made to teachers and other non-law enforcement personnel are less likely to be testimonial. Extended analysis beyond police interrogations to consider broader context of when statements are made.

Hardy v. Cross - What was addressed?

Addressed application of Confrontation Clause principles in specific factual context, applying the framework from Crawford and its progeny.

What does the Sixth Amendment Compulsory Process Clause provide according to case law?

The Sixth Amendment provides that defendants have “compulsory process for obtaining witnesses in his favor.” This means: (1) right to obtain witnesses, documents, and evidence needed for defense; (2) right to present witnesses and evidence at trial; (3) right to present a complete defense. Courts have enforced this to prevent arbitrary restrictions on defense evidence

In re Winship - What was the holding?

Holding: The Due Process Clause “protects the accused from conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.” Established beyond reasonable doubt as constitutional requirement, not just common law rule. Based on: (1) presumption of innocence; (2) preventing false convictions; (3) seriousness of criminal convictions; (4) community confidence

Herring v. New York - What was the holding?

Holding: The closing argument is a vital part of the adversarial process because it permits both sides to submit their complete case to the jury. Denying the opportunity for closing argument violates due process and the right to counsel.

Dunlop v. United States - What was addressed?

Addressed limitations on closing arguments and what types of arguments are impermissible, establishing standards for reviewing prosecutorial misconduct in closing.

Donnelly v. DeChristoforo - What was the holding?

Holding: Addressed standards for evaluating whether prosecutorial remarks in closing argument require reversal. Court must consider remarks in context of entire trial; not every improper remark requires reversal - must assess prejudicial impact

Apodaca v. Oregon - What was the holding?

Holding: States are NOT constitutionally required to have unanimous jury verdicts in criminal cases. Non-unanimous verdicts (such as 10-2 or 11-1) do not violate the Sixth Amendment. (Note: This remains controversial and some recent decisions have questioned this holding.)

Johnson v. Louisiana - What was the holding?

Holding: Upheld Louisiana’s 9-3 jury verdict system against constitutional challenge. Along with Apodaca, established that states have flexibility regarding unanimity requirements (though federal courts still require unanimity).

Burch v. Louisiana - What was the holding?

Holding: While states are not required to have unanimous 12-person juries, six-person juries MUST be unanimous. A 5-1 verdict from a six-person jury violates the Sixth Amendment. This sets a floor for non-unanimous verdicts.

Sparf and Hansen v. United States - What was the holding?

Holding: Juries do not have a RIGHT to be instructed about jury nullification. While juries have the POWER to acquit against the evidence (which cannot be reviewed), courts need not inform juries of this power. Judges should instruct on the law as written

United States v. Washington - What was addressed?

Addressed jury nullification in context of specific case, following principles from Sparf that courts need not instruct on nullification power

United States v. Dougherty - What was the holding?

Holding: Affirmed that while jury nullification exists as a power, defendants have no right to have juries instructed about it. Courts can refuse defense requests to tell jurors they can disregard the law. The power exists as a safety valve, but informing juries might encourage lawless verdicts

What constitutional issues do guilty pleas raise according to case law?

Guilty pleas implicate: (1) Fifth Amendment right against self-incrimination (waived by pleading guilty); (2) Sixth Amendment right to jury trial (waived); (3) Sixth Amendment right to confront witnesses (waived). Courts have upheld plea bargaining as constitutional if pleas are KNOWING, VOLUNTARY, and INTELLIGENT, with adequate factual basis.