Sunday, November 3, 2013

Williams v. Florida case brief

Williams v. Florida case brief summary
399 U.S. 78 (1970)

CASE SYNOPSIS
Petitioner, who had been convicted of robbery, sought review of judgment of District Court of Appeal (Florida), which affirmed a denial of petitioner's request to be excused from requirements of Fla. R. Crim. P. 1.200 despite petitioner's argument that the rule violated hisU.S. Constitutional Amendment V and VI rights. Petitioner also sought review of the denial of his motion to impanel a 12-man jury instead of six-man jury provided by Florida law.

CASE FACTS
Prior to his trial for robbery in the state of Florida, petitioner filed a motion, which was subsequently denied, for a protective order in which he sought to be excused from the requirements of Fla. R. Crim. P. 1.200. Pursuant to that rule, a defendant was required, on the written demand of the prosecutor, to give notice in advance of trial of his intention to claim an alibi and to furnish information as to the place where he would claim to have been and with the names and addresses of the alibi witnesses he intended to use. Petitioner claimed the rule required him to be a witness against himself in violation of his U.S. Constitutional Amendment V and XIV rights. Petitioner also argued that the denial of his motion to impanel a 12-man jury instead of the six-man jury provided by Florida law in such cases, was a violation of his U.S. Constitutional Amendment V and VI rights.

DISCUSSION
On appeal, the Supreme Court concluded that the privilege against self-incrimination had not been violated by the requirement of Fla. R. Crim. P. 1.200 because such information had not been compelled. The Court also held that a 12-man panel was not a necessary ingredient of trial by jury, but had merely been a historical accident.

CONCLUSION

The judgment was affirmed as to the Florida criminal procedure statute because the Supreme Court concluded that the privilege against self-incrimination had not been violated. In arriving at that outcome, the Court noted that the statute did not compel defendants, such as petitioner, to give any such information. The judgment was also affirmed as to the jury issue because a 12-man panel was not a necessary ingredient of trial by jury.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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