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Sixth Amendment Court Cases - Compulsory Process
Clause
Each of
these Sixth Amendment Court Cases is somehow significant to the way
the Supreme Court has interpreted the Compulsory Process Clause in the
Sixth Amendment to the US
Constitution. Well, most are significant, some are just interesting! You
can read about the history and meaning of the Sixth Amendment here.
Sixth
Amendment Court Cases
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Supreme Court
of the United States
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Like all provisions in the Bill of Rights, the 6th Amendment's
Compulsory Process Clause was originally applied only to the Federal
government and not to the states. After the Civil War, the 14th
Amendment was passed to ensure that African-Americans were treated
equally with other citizens. The Supreme Court gradually began to
require the states to abide by the Bill of Rights as well, through its
interpretation of the 14th Amendment's Due Process Clause. You
can read the 14th Amendment here.
Sixth
Amendment Court Cases - Compulsory
Process Clause cases - Washington
vs. Texas
Washington
vs. Texas, 1967, was the case the Court used to apply the
Compulsory Process Clause to the States. This case also overturned a
Texas law that barred defendants from calling witnesses who had been
accomplices in the same alleged crime.
In this case, the accomplice's testimony was allowed to be used by the
prosecutor, but the defendant could not call the accomplice to testify
on his behalf, according to the Texas statute. The only way the
accomplice could have testified in the defendant's behalf is if the
accomplice had been acquitted of the charges.
The Court ruled that this was a violation of the Compulsory Process
Clause's provision that the defendant can call for witnesses to testify
in his behalf. The Court's decision said:
"It is difficult to see how the
Constitution is any less violated by the arbitrary rules that prevent
whole categories of defense witnesses from testifying on the basis
of... categories that presume them unworthy of belief."
Sixth
Amendment Court Cases - Compulsory
Process Clause cases - Webb
vs. Texas
In Webb vs. Texas,
1972, a trial court judge had given the defendant's only witness a
lengthy admonition about not lying to the court, accompanied with very
stern warnings about the consequences of doing so. The judge scared the
witness so much that he refused to testify at all.
The Court ruled that the judge had violated the defendant's 6th
Amendment Compulsory Process Clause right to present his own witnesses
in his defense.
Sixth
Amendment Court Cases - Compulsory
Process Clause cases - Roviaro
vs. United States
In Roviaro vs. United
States, 1957, the defendant was charged with and
convicted for knowingly possessing and transporting heroin. The
government had used an undercover informant in the matter, who was
directly involved in bringing about the defendant's possession of the
drugs. The informer was there at the time with the defendant when the
crime allegedly occurred.
The defense requested the name and address of the informer because it
wanted to cross-examine him. The informer may have been able to shed
light on the circumstances, especially whether or not the defendant
understood that he was carrying drugs. The government refused this
request on the grounds that it had the privilege to keep the identity
of the informer secret.
The Supreme Court disagreed. The Court said that a formal rule could
not be made in circumstances where an undercover informer is involved.
Each case must be weighed according to its circumstances. Sometimes it
may be justified in keeping the identity of the informer secret. But in
this case, the Court said, the overriding interest was the defendant's
6th Amendment Compulsory Process Clause right to produce witnesses in
his own defense. The informer was directly involved and probably had
important knowledge of the matter that the defense would want to bring
out in court.
The Court gave four factors that must be judged when considering
whether or not the identity of the informer must be revealed. The
ruling said the following:
The four factors to be considered are:
- The nature of the alleged crime
- The possible defenses of the accused
- The possible significance of the informer's
testimony
- Any other relevant factors or circumstances
Read
more about the history and meaning of the Compulsory Process Clause
here.
Read
more about the history and meaning of the 6th Amendment here.
Learn more about Sixth Amendment Cases relating to the
following
Sixth Amendment clauses:
Sixth
Amendment Court Cases -
Speedy
Trial Clause
Sixth
Amendment Court Cases -
Public
Trial Clause
Sixth
Amendment Court Cases -
Right
to Trial by Jury Clause
Sixth Amendment Court Cases - Arraignment
Clause
Sixth
Amendment Court Cases - Confrontation
Clause
Sixth
Amendment Court Cases -
Right
to Counsel Clause
If
you would like
to read about the meanings of each amendment, go to
the First
Ten Amendments page here.
Amendments:
Preamble
to the Bill of Rights
Learn
about the 1st Amendment here.
Learn
about the 2nd Amendment here.
Learn
about the 3rd Amendment here.
Learn
about the 4th Amendment here.
Learn
about the 5th Amendment here.
Learn
about the 6th Amendment here.
Learn
about the 7th Amendment here.
Learn
about the 8th Amendment here.
Learn
about the 9th Amendment here.
Learn
about the 10th Amendment here.
Read
the Bill of Rights here.
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