Monday, December 23, 2013

Parker v. Gladden case brief

Parker v. Gladden case brief summary
385 U.S. 363 (1966)

CASE SYNOPSIS
Petitioner inmate sought review of a judgment of the Supreme Court of Oregon, which reversed a trial court order granting the inmate's request for post-conviction relief. The inmate had been convicted of second degree murder.

CASE FACTS
The bailiff assigned to escort the jury during the inmate's murder trial told one juror in the presence of others that he was guilty. In similar circumstances, he also told a juror that the state supreme court would correct the conviction if there was anything wrong with it. After he was convicted, the inmate filed a petition seeking post-conviction relief, which the trial court granted after finding that the unauthorized communication was prejudicial and that the bailiff's conduct materially affected the inmate's rights. The state supreme court reversed, ruling that the misconduct did not deprive the inmate of a constitutionally correct trial.

DISCUSSION

  • On certiorari, the Court determined that the bailiff's statements were controlled by the command of the Sixth Amendment, made applicable to the states through the Due Process Clause of the Fourteenth Amendment, which guaranteed that an accused would enjoy the right to a trial by an impartial jury and to be confronted with the witnesses against him. 
  • The bailiff was an officer of the court and the State, so his unauthorized conduct involved such a probability that prejudice would result that it was deemed inherently lacking in due process.

CONCLUSION
The Court reversed the state supreme court's judgment reversing that of the trial court, which had granted the inmate's petition for post-conviction relief.

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