Chambers v. Mississippi
410 U.S. 284, 93 S.Ct. 1038, 35 L.Ed.2d 297 (1973)
- During a riot, a police officer named Liberty was shot and killed. Chambers was arrested and charged with murder.
- Chambers argued that Liberty had been shot by a guy named McDonald.
- Chambers had the testimony of two witnesses who claimed to have seen McDonald shoot Liberty, a sworn confession written by McDonald to Chamber’s lawyer, and three witnesses who claimed that McDonald told them he shot Liberty.
- At trial, Chambers put McDonald on the witness stand to swear to the validity of the out-of-court confession. However, McDonald repudiated the confession and testified that he did not shoot Liberty.
- At the time Mississippi did not have an exception to hearsay for statements against penal interest. If they did, then McDonald’s confession could have been admitted under that exception.
- Chambers attempted to cross-examine McDonald as an adverse witness, but the Trial Judge refused to allow the cross examination. The Trial Judge further refused to allow the testimony of the three witnesses who claimed that McDonald told them he shot Liberty.
- Under Mississippi State common law, a party may not impeach their own witness.
- Basically, since Chambers had called McDonald to the stand, he could not present evidence that McDonald was lying.
- The idea that a party is forbidden from impeaching their own witness is known as the voucher rule, and it is based on the presumption that a party who calls a witness vouches for their credibility.
- Chambers was convicted of murder. He appealed.
- The Mississippi Supreme Court affirmed. Chambers appealed.
- The US Supreme Court reversed and remanded for a new trial.
- The US Supreme Court found that the voucher rule has its basis in ancient times, when witnesses were partisan and routinely lied under oath. That has little relation to modern criminal trials.
- The Court found that the voucher rule clearly violated Chambers’ 6th Amendment right to defend himself. Since there was insufficient due process, the case is remanded for a new trial.
- This case was decided under the common law. Today it would be governed by FRE 607, which says that any party can attempt to impeach the credibility of any witness.