Monday, November 4, 2013

Simmons v. United States case brief

Simmons v. United States case brief summary
390 U.S. 377 (1968)

Petitioners appealed a decision of the United States Court of Appeals for the Seventh Circuit, which convicted them of armed robbery. Petitioners alleged due process violations arising out of a suggestive photo lineup, Jencks Act violations arising from the denial of production of photographs of petitioners used at trial, and a constitutional right violation caused by the admission of former testimony against one petitioner.

The first petitioner alleged that a pretrial photographic identification was unnecessarily suggestive and conducive to misidentification, denying him due process of law. Petitioners argued that it was error to refuse requests for production under the Jencks Act, 18 U.S.C.S. § 3500, of petitioners' photographs shown prior to trial. The second petitioner alleged that his constitutional rights were violated when testimony in support of a suppression motion was admitted against him at trial.

  • The Court held that under the factual circumstances, the first petitioner's due process rights were not violated because the photos were not shown at a "critical stage" of prosecution. 
  • The Jencks Act was not violated, as the photographs were not incorporated in written statements of witnesses, as required by § 3500. 
  • When the second petitioner testified in support of his suppression motion on U.S. Constitutional Amendment IV grounds, his testimony could not be admitted against him at trial on the issue of guilt unless he waived his U.S. Constitutional Amendment V privilege against self-incrimination.

The Court affirmed the armed robbery conviction as to the first petitioner. The court reversed the judgment as to the second petitioner and remanded the case to the court of appeals for further proceedings.

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

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