Johnson v. New Jersey

Supreme Court of the United States · 1966 · Federal Courts

Federal CourtsRetroactivityCriminal ProcedureConfessionsSelf-IncriminationRight to CounselretroactivityEscobedo

Facts

Johnson and Cassidy were convicted of first-degree murder after their recorded confessions were admitted at a joint trial in 1958. In later collateral proceedings following Escobedo, they filed affidavits alleging for the first time that police denied requests to contact counsel or relatives and blocked relatives' efforts to reach them; the state court accepted those allegations as true for resolving the Escobedo issue. Their convictions had become final years before Escobedo and Miranda were decided, and they had repeatedly but unsuccessfully challenged the voluntariness of their confessions in earlier proceedings. The New Jersey Supreme Court held Escobedo did not apply to convictions final before that decision and relied on a state procedural rule to bar renewed consideration of the coerced-confession claim based on the new allegations.

Issue

Whether Escobedo v. Illinois and Miranda v. Arizona apply retroactively to convictions obtained at trials completed before those decisions were announced. Also, whether those decisions should apply to cases still on direct appeal or only to cases in which trial began after the decisions, and whether the Court could review petitioners' renewed coerced-confession claim in light of the state procedural bar.

Rule

The retroactivity of a new constitutional rule of criminal procedure is determined case by case by considering the purpose of the new rule, the extent of reliance on prior law, and the effect of retroactive application on the administration of justice. Under that analysis, Escobedo applies only to cases in which trial began after June 22, 1964, and Miranda applies only to cases in which trial began after June 13, 1966. A state procedural ground that is adequate bars Supreme Court review of a claim presented in violation of that state rule.

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

In Cleveland, Omar Bennett was questioned in police custody in March 1964 and made incriminating statements after officers refused his request to call a lawyer. His state murder trial began on July 10, 1964, and the statements were admitted over objection.

On federal review, which is the strongest argument regarding Omar's ability to invoke the counsel-during-interrogation rule later announced in 1964?

Explanation. The majority measured prospectivity by when the trial began, not when the interrogation occurred and not by finality alone. The 1964 interrogation rule applies only to cases in which trial began after June 22, 1964. Because Omar's trial began after that date, he may invoke that rule.