Estelle v. Williams 425 U.S. 501 , is a trial which involved the accused Harry Lee Williams murdering his former landlord in Harris County, Texas

Harris County, Texas

As of the 2010 Census, the population of the county was 4,092,459, White Americans made up 56.6% of Harris County's population; non-Hispanic whites represented 33.0% of the population. Black Americans made up 18.9% of the population. Native Americans made up 0.7% of Harris County's population...

. While awaiting trial Williams was unable to post bail. Because he was unable to post bail he was tried in his prison uniform, and later was found guilty. He sought a writ of habeas corpus saying it violated his Constitutional rights in accordance with the 14th amendment. The Court of Appeals ruled that the accused does not have to withstand trial in identifiable prison cloths and Williams’ right to due process was violated. His rehearing was denied by the Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 on June 21, 1976.

Background

Section one of the Fourteenth Amendment

Fourteenth Amendment to the United States Constitution

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...

 of the Constitution

Constitution

A constitution is a set of fundamental principles or established precedents according to which a state or other organization is governed. These rules together make up, i.e. constitute, what the entity is...

 states “No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws”. The argument made by Williams was that wearing clearly identifiable prison clothes had given a perception of guilt and therefore undermines his right to innocence until proven guilty under due process. The violation of his amendment rights would allow him to appeal for a mistrial if upheld in the Court.

Historical context

In the case of Chapman v. California  (1967) the court ruled that some mistakes and errors could be made that do not require rectification. The defendants in the case invoked the 5th amendment and chose not to testify. They were eventually were found guilty, but appealed on the basis that their silence created negative publicity which skewed the views of the jurors and undermined their trial. The court agreed that negative media hype was high, but concluded that this occurrence had no effect on the outcome of the trial, and therefore did not require any modification. However, the court went on to say each case is particular and the stances should be viewed individually. The error would have to be found insignificant to the overall outcome of the trial in order to not be overturned. The court must find the error to be harmless without a doubt in order for the verdict to be considered final. If the appeal happens to be upheld, the defendant can be awarded a retrial.

In Hernandez v. Beto (1971), the accused Hernandez appealed to the court for being tried in prison clothes. Hernandez had not made a request to be tried in his civilian clothes and therefore the prosecutor maintains that if there was an error made it was harmless. The District Court referenced Brooks v. Texas (1967) and set the precedent that it is implicitly wrong to try a defendant in prison attire especially when civilian clothing is at hand. The appearance of the prison uniform should not be able to affect the jurors’ decision making, which should solely be left to be judged on the hard evidence alone. The judge at Hernandez’s trial referenced the decision in Brooks v. Texas and agreed that the situation is applicable to the case at hand. The Court of Appeals however found that since no objection was made by the defendant to wearing prison clothes then his appeal for retrial was denied.
In Turner v. Louisiana (1965) the appeal allowed the defendant, Turner, to have the decision reversed and remanded. During Turner’s three day trial for murder, the two deputy sheriffs who had custody of the jury and closely interacted with them during this time were the two main witnesses in his case. The appeal on a writ of habeas corpus was upheld on the basis that Turner’s fourteenth amendment rights were violated because of his right to an impartial jury under due process.

Central Conflict

The accused Williams went to his former residence to visit a female friend. While there he got into a confrontation with his former landlord in respect to his failed payments. Williams ended up stabbing the landlord multiple times in the back and abdomen. He was brought up on charges of assault with intent to murder with malice. Williams was unable to post bail and stayed in jail until his court date on October 7, 1975. Williams requested his civilian clothes from the police officer in charge of his detainment, he was denied. He underwent trial in Harris County, Texas, and the court found him guilty. After, he asked for a writ of habeas corpus for being forced to stand trial in prison clothing. The District Court denied assistance but the Court of Appeals took up his case which was eventually brought in front of the Supreme Court .

Opinion of the Court

The Court believes that due process was denied to Harry Lee Williams. However, some believed that it was a procedural error by his lawyer while others alleged he was compelled to wear them when he was denied his civilian clothes. The essential and shared belief of the court was that Williams did not make a timely objection to his appearance in prison attire and therefore although he was denied due process, his claim was insignificant in the court of law. Justice Stevens took no part in the decision of this particular case.

Concurrence

Justice Powell said, “‘Courts [also] have required an accused to object to being tried in jail garments, just as he must invoke or abandon other rights.’ Here, ‘[t]he record is clear that no objection was made to the trial judge concerning the jail attire either before or at any time during the trial. This omission plainly did not result from any lack of appreciation of the issue, for respondent had raised the question with the jail attendant prior to trial. At trial, defense counsel expressly referred to respondent’s attire during voir dire. The trial judge was thus informed that respondent’s counsel was fully conscious of the situation’”. The Court ruled 6-2 that Williams wearing his prison clothes was considered harmless because of a failure to make a timely objection. Williams’ appeal was refuted and a retrial was denied due to his lack of an objection to the judge despite clearly being aware of his appearance. Justices Powell and Stewart agreed that Williams’ attorney made “an inexcusable procedural default” or “tactical choice” which allowed for Williams’ appearance and therefore was liable on his own accord despite being denied due process.

Dissenting Opinion

The two votes in favor of Williams came from the Justices Marshall and Brennan. Since Williams was in prison garb he gave the appearance of guilt. In Coffin v. United States it is stated “the principle that there is a presumption of innocence in favor of the accused is the undoubted law, axiomatic and elementary, and its enforcement lies at the foundation of the administration of our criminal law”. The appearance of Williams in prison garments corrupted the court process and therefore the error in the court cannot be considered “harmless beyond a doubt.” Justice Marshall said, “the Court could not rest the reversal on a finding that respondent knowingly, voluntarily, and intelligently consented to be tried in such attire, and thus had waived his due process right”. The defendant never conceded to wearing his prison clothes while on trial and a retrial should be awarded because of the violation of his fourteenth amendment rights under due process.

Historical Significance

The court’s decision upheld the previous decisions regarding defendants wearing prison uniforms without objection in a timely manner. The opinion of the court was that Williams’ due process rights had been violated since he had not consented to wearing the clothing while on trial. In relation to other trials, the justices went on to agree that the waiving of due process rights must be done consciously and intelligently. If the defendant does not knowingly waive his rights then the court must rule the error harmless beyond a doubt or the accused can be awarded a retrial.