Griffin v. Illinois
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| Griffin v. Illinois | |
| Reference: 351 U.S. 12 | |
| Term: 1955 | |
| Important Dates | |
| Argued: December 7, 1955 Decided: April 23, 1956 | |
| Outcome | |
| Supreme Court of Illinois vacated and remanded | |
| Majority | |
| Chief Justice Earl Warren • Hugo Black • Tom Clark • William O. Douglas | |
| Concurring | |
| Felix Frankfurter | |
| Dissenting | |
| Harold Burton • John M. Harlan • Sherman Minton • Stanley Reed | |
Griffin v. Illinois was decided on April 23, 1956, by the U.S. Supreme Court, which held that states could not deny an appeal of a criminal conviction to people who could not afford to access the necessary transcripts and records. The case concerned an Illinois law that required individuals appealing a criminal conviction to furnish either a bill of exceptions or a certified report of the trial proceedings at their own expense. The court vacated and remanded the decision of the Supreme Court of Illinois, ruling that the Illinois law violated the Due Process Clause and Equal Protection Clause of the Fourteenth Amendment.[1]
Why it matters: The court ruled in Griffin that states had to assist indigent people with criminal convictions in accessing the records necessary to appeal those convictions.
Background
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Judson Griffin and James Crenshaw, the petitioners in this case, were tried together and convicted of armed robbery in Cook County, Illinois. They sought to appeal their conviction and petitioned the trial court for a certified copy of the trial record including a stenographic transcript of the trial proceedings. Under Illinois law, in order to receive a full review of alleged judicial errors, an appellant was required to provide the appellate court with either a bill of exceptions or a judicial report of the trial proceedings certified by the trial judge. Illinois stipulated that these records were difficult to prepare absent a stenographic transcript. These transcripts were provided to capital defendants at cost to the county, but appellants had to pay for them in all other instances. Griffin and Crenshaw "alleged that that they were 'poor persons with no means of paying the necessary fees to acquire the Transcript and Court Records needed to prosecute an appeal,'" allegations that Illinois did not contest. Griffin and Crenshaw further stated that if the trial court failed to provide a transcript, such an action would constitute a violation of their rights of due process and equal protection under the Fourteenth Amendment to the U.S. Constitution. The trial court denied Griffin and Crenshaw's motion without a hearing.[1]
Griffin and Crenshaw then filed a petition under the Illinois Post-Conviction Act, which provided certain indigent appellants with a free transcript to obtain review of state or federal constitutional questions. In their motion, both appellants alleged "there were manifest nonconstitutional errors in the trial which entitled them to have their convictions set aside on appeal and that the only impediment to full appellate review was their lack of funds to buy a transcript." Griffin and Crenshaw also reiterated their point made to the trial judge that denying them a transcript on the basis of their indigence violated their rights to due process and equal protection under the U.S. Constitution. The appellate court dismissed their petition without a hearing. The Supreme Court of Illinois affirmed the dismissal "solely on the ground that the charges raised no substantial state or federal constitutional questions - the only kind of questions which may be raised in Post-Conviction proceedings." Griffin and Crenshaw petitioned the U.S. Supreme Court, which granted certiorari.[1]
Oral argument
Oral argument was held on December 7, 1955.[1]
Decision
The judgment of the Supreme Court of Illinois was vacated and remanded.[1]
Opinions
Opinion of the court
Justice Hugo Black delivered the opinion of the court for four justices, including himself, and announced the judgment of the court for a five-justice majority. Justice Felix Frankfurter concurred in the judgment but wrote a separateopinion. In his opinion for the court, Justice Black argued that there was no difference between denying the rights of the poor at trial with denying the rights of the poor on appeal:[1]
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In criminal trials a State can no more discriminate on account of poverty than on account of religion, race, or color. Plainly the ability to pay costs in advance bears no rational relationship to a defendant's guilt or innocence and could not be used as an excuse to deprive a defendant of a fair trial ... There is no meaningful distinction between a rule which would deny the poor the right to defend themselves in a trial court and one which effectively denies the poor an adequate appellate review accorded to all who have money enough to pay the costs in advance. It is true that a State is not required by the Federal Constitution to provide appellate courts or a right to appellate review at all ... But that is not to say that a State that does grant appellate review can do so in a way that discriminates against some convicted defendants on account of their poverty. Appellate review has now become an integral part of the Illinois trial system for finally adjudicating the guilt or innocence of a defendant. Consequently at all stages of the proceedings the Due Process and Equal Protection Clauses protect persons like petitioners from invidious discriminations ... There can be no equal justice where the kind of trial a man gets depends on the amount of money he has. Destitute defendants must be afforded as adequate appellate review as defendants who have money enough to buy transcripts. [2] |
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In vacating and remanding the decision of the Supreme Court of Illinois, Justice Black said that mandating adequate appellant review to all indigent defendants did not require that the state had to provide records or transcripts in all instances as long as other means of adequate appellant review were provided.
Concurrence
Justice Felix Frankfurter, who concurred in the judgment of the court but did not join Justice Black's opinion, argued that due process did not require states to provide criminal appeals at all and that the equal protection clause did not deny a state the right to make classifications within the law that were rooted in reason. Justice Frankfurter said, "[N]either the fact that a State may deny the right of appeal altogether nor the right of a State to make an appropriate classification, based on differences in crimes and their punishment, nor the right of a State to lay down conditions it deems appropriate for criminal appeals, sanctions differentiations by a State that have no relation to a rational policy of criminal appeal or authorizes the imposition of conditions that offend the deepest presuppositions of our society."[1]
Justice Frankfurter said Illinois had a right to "protect itself so that frivolous appeals are not subsidized and public moneys not needlessly spent." But he argued that the state had to provide Griffin and Crenshaw either a transcript or some other similarly satisfactory evidentiary foundation provided under Illinois law for their appeal.
Justice Frankfurter also said that because, in the court's view, the decision did not impart a new standard in the law, many defendants could be treated as having unfairly waived their right to appellate review. Justice Frankfurter took exception to this, arguing that the court's announcement should constitute a new holding in the law through which those convicted previously could seek relief.[1]
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We must be mindful of the fact that there are undoubtedly convicts under confinement in Illinois prisons, in numbers unknown to us and under unappealed sentences imposed years ago, who will find justification in this opinion, unless properly qualified, for proceedings both in the state and the federal courts upon claims that they are under illegal detention in that they have been denied a right under the Federal Constitution. It would be an easy answer that a claim that was not duly asserted - as was the timely claim by these petitioners - cannot be asserted now. The answer is too easy. Candor compels acknowledgement that the decision rendered today is a new ruling. Candor compels the further acknowledgement that it would not be unreasonable for all indigent defendants, now incarcerated, who at the time were unable to pay for transcripts of proceedings in trial courts, to urge that they were justified in assuming that such a restriction upon criminal appeals in Illinois was presumably a valid exercise of the State's power at the time when they suffered its consequences. Therefore it could well be claimed that thereby any conscious waiver of a constitutional right is negatived ... For sound reasons, law generally speaks prospectively ... We should not indulge in the fiction that the law now announced has always been the law and, therefore, that those who did not avail themselves of it waived their rights. It is much more conducive to law's self-respect to recognize candidly the considerations that give prospective content to a new pronouncement of law. [2] |
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Dissents
Justices Harold Burton and Sherman Minton jointly authored a dissenting opinion joined by Justices John Harlan and Stanley Reed. In the dissent, Justices Burton and Minton assessed whether the law under review in the case denied due process or equal protection. The authors quickly dismissed the due process claim in arguing that "to allow an appeal at all, but with some difference among convicted persons as to the terms upon which an appeal is exercised, does not deny due process."
In assessing Griffin and Crenshaw's equal protection claim, the justices argued that Illinois' rule, which distinguished between capital and noncapital defendants for gaining free transcripts of the trial record, was a reasonable and valid distinction for the Illinois legislature to make and was neither arbitrary nor unreasonable. The justices argued that since every criminal defendant could partake in the appeals process, the law did not violate equal protection. In the dissenting justices' view, "The Constitution requires the equal protection of the law, but it does not require the States to provide equal financial means for all defendants to avail themselves of such laws."
Justice Harlan, in addition to joining the principal dissent, wrote a separate dissent agreeing with the dissent's main contentions regarding due process and equal protection but stipulating also that he would remand the case to the Illinois courts "for further proceedings so that we might know the precise nature of petitioners' claim before passing on it."[1]
See also
- Supreme Court of the United States
- History of the Supreme Court
- Douglas v. California
- Ross v. Moffitt
External links
Footnotes
