Washington v. Texas
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| Washington v. Texas | |
| Reference: 388 US 14 | |
| Term: 1967 | |
| Important Dates | |
| Argued: March 15 - 16, 1967 Decided: June 12, 1967 | |
| Outcome | |
| Texas Court of Criminal Appeals reversed | |
| Majority | |
| Earl Warren • Hugo Black • William Douglas • Tom Clark • John Harlan • William Brennan • Potter Stewart • Byron White • Abe Fortas | |
Washington v. Texas is a case decided 9-0 on June 12, 1967, by the United States Supreme Court holding a Texas statute prohibiting persons charged together in the same crime from testifying for each other violated the Sixth Amendment right to compulsory process. This right is incorporated under the Due Process Clause of the Fourteenth Amendment. The court reversed the decision of the Texas Court of Criminal Appeals.[1][2]
Why it matters: The Supreme Court's decision found that the Texas statute that barred persons charged together in the same crime from testifying for each other to be in violation of the Sixth Amendment's right to compulsory process. To read more about the impact of Washington v. Texas click here.
Background
Jackie Washington and Charles Fuller were charged and arrested for murder in Dallas County, Texas. Prior to the shooting, Jackie Washington was dating a girl by the name of Jean Carter. They were forced to end their relationship after Jean’s mother forbid her from seeing him. Jean Carter soon began dating another boy. On the night of August 29, 1964, Jackie Washington, Charles Fuller, and some other boys went to Jean Carter's house, where she was having dinner with her family and her new boyfriend. Fuller approached the house with a loaded shotgun while Jackie Washington was allegedly trying to convince him to leave. Fuller did not listen and shot Jean Carter's boyfriend on her front porch.
Charles Fuller was tried first and convicted of murder. At Washington's trial for the same murder, he sought to have Charles Fuller testify that Fuller was the one who shot the victim while Jackie Washington was simply trying to stop the shooting from happening. This testimony would have been vital for his defense. At the time of trial, there were two Texas statutes in place that prevented a defendant accused of a crime from testifying for their coparticipant. The prosecution objected to Washington's motion to have Fuller testify at his trial. The judge overseeing the case sustained the state's objection to Charles Fuller's testimony. Washington was sentenced to 50 years in prison. His defense appealed on the basis that the state violated his Sixth Amendment right to compulsory process by not allowing Charles Fuller to testify. The Texas Court of Criminal Appeals affirmed his conviction, rejecting the notion that Washington's rights were violated.[2]
Oral argument
Oral arguments were held on March 15-16, 1967. The case was decided on June 12, 1967.[1]
Decision
The Supreme Court decided 9-0 to reverse the Texas Court of Criminal Appeals decision. Chief Justice Earl Warren delivered the opinion of the court, with Justice John Harlan writing a concurring opinion.[2]
Opinions
Opinion of the court
Chief Justice Earl Warren, writing for the court, argued that the right to compulsory process was applicable to the states through the Fourteenth Amendment's Due Process Clause:[2]
| “ | We hold that the petitioner in this case was denied his right to have compulsory process for obtaining witnesses in his favor because the State arbitrarily denied him the right to put on the stand a witness who was physically and mentally capable of testifying to events that he had personally observed, and whose testimony would have been relevant and material to the defense. [Footnote 21] The Framers of the Constitution did not intend to commit the futile act of giving to a defendant the right to secure the attendance of witnesses whose testimony he had no right to use. The judgment of conviction must be reversed.[3] | ” |
| —Earl Warren, majority opinion in Washington v. Texas[2] | ||
Concurring opinions
Justice John Harlan wrote a concurring opinion, arguing that Jackie Washington's constitutional right to due process was violated and that the Texas statute discriminated against defendants by allowing the prosecution to call witnesses involved in the same offense. He delineated from the majority opinion by rejecting the notions that the petitioner's right to compulsory process played a role in the case and that such a right is applicable to states through the Fourteenth Amendment::[2]
| “ | I concur in the result in this case because I believe that the State may not constitutionally forbid the petitioner, a criminal defendant, from introducing on his own behalf the important testimony of one indicted in connection with the same offense, who would not, however, be barred from testifying if called by the prosecution. Texas has put forward no justification for this type of discrimination between the prosecution and the defense in the ability to call the same person as a witness, and I can think of none.
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| —John Harlan, concurring opinion in Washington v. Texas[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Washington v. Texas incorporated the Sixth Amendment's right to compulsory process against the states through the Due Process Clause outlined in the Fourteenth Amendment. The case established the precedent that state courts cannot deny persons charged together in the same crime from testifying for each other.[1][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Washington v. Texas," accessed August 29, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 Justia, "Washington v. Texas, 388 U.S. 14 (1967)," accessed August 29, 2022
- ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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