Sunday, November 3, 2013

Williams v. New York case brief

Williams v. New York case brief summary
337 U.S. 241 (1949)

Defendant challenged a judgment of the Court of Appeals of New York, which affirmed his first-degree murder conviction and death sentence.

Defendant was convicted of first-degree murder for a killing that occurred during a robbery. The jury recommended life imprisonment, but the trial court imposed the death sentence. In sentencing defendant, the trial court considered a probation report that had been prepared about him. Defendant challenged the judgment, arguing that his sentence violated the Due Process Clause of U.S. Constitutional Amendment XIV because the trial court considered information supplied by witnesses that defendant had not confronted and cross-examined. On appeal, the Court affirmed.

  • The Court held that the Due Process Clause did not prevent the trial court from considering the probation report in sentencing appellant, given the historical background and practical reasons for the different evidentiary rules governing trials and sentencing procedures. 
  • The probation report, which drew on information concerning every aspect of defendant's life, was invaluable to the trial court in making its sentencing decision, and given the type and extent of information included in the report, it would have been impractical if not impossible to have presented it in open court with cross-examination.


The judgment was affirmed because the Due Process Clause did not prohibit the trial court from considering a probation report prepared on defendant when sentencing him to death.

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

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