Chambers v. Mississippi

Supreme Court of the United States · 1973 · Evidence

410 U.S. 284 (1973)

Updated August 1, 2026

Evidencedue process right to present evidencedue processright to present a defensecross-examinationconfrontationvoucher ruleparty witness rule

Facts

At trial for murdering Officer Liberty, Chambers claimed both that he did not shoot Liberty and that Gable McDonald was the shooter. McDonald had given a sworn confession to Chambers' attorneys admitting the shooting, but later repudiated that confession and testified at trial that he did not shoot Liberty and was elsewhere when the shooting occurred. After Chambers called McDonald, Mississippi's voucher rule prevented Chambers from cross-examining him as an adverse witness, and the trial court also excluded as hearsay testimony from three witnesses who would have recounted McDonald's separate out-of-court confessions. Other evidence tended to corroborate McDonald's confessions, including eyewitness testimony that McDonald shot Liberty, testimony that McDonald had a gun immediately afterward, and proof that he owned a .22-caliber revolver.

Issue

Whether Chambers was denied due process when Mississippi's voucher rule prevented him from effectively cross-examining McDonald after McDonald repudiated his confession, and when the hearsay rule barred testimony from other witnesses that McDonald had separately confessed to the murder. More broadly, the question was whether the combined application of these evidentiary rules deprived Chambers of a fair opportunity to present his defense.

Rule

The right to due process includes a fair opportunity to defend against the State's accusations, including the rights to confront and cross-examine witnesses and to call witnesses in one's own behalf. Although states may enforce ordinary evidentiary rules, those rules may not be applied mechanistically to defeat the ends of justice when constitutional rights affecting the ascertainment of guilt are implicated. Where excluded hearsay bears persuasive assurances of trustworthiness and is critical to the defense, and where the defendant is also denied effective cross-examination of a seriously adverse witness, the combined exclusions violate due process.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a murder trial in Ohio, Devin Cole argues that another man, Nolan Price, was the shooter. Nolan appears at trial, denies involvement, and gives an alibi that, if believed, strongly points back to Devin. State law prevents Devin from cross-examining Nolan because Devin called him as a witness, and the court also excludes three witnesses who would testify that Nolan separately confessed to the shooting within hours of the crime.

If the excluded confession testimony was strongly corroborated by other evidence and was central to Devin's defense, which is the strongest argument on appeal?

Explanation. The majority held that due process is violated when evidentiary rules are applied mechanistically to block a fair opportunity to defend, especially where the defendant is denied effective cross-examination of a seriously adverse witness and also prevented from introducing critical, trustworthy third-party confessions. The witness's being called by the defense does not eliminate the confrontation concern when his testimony is in fact damaging.