Williams v. Florida
Encyclopedia
Williams v. Florida was a case decided by the Supreme Court of the United States
, argued on 4 March 1970 and decided on 22 June 1970. The Court held that the Fifth Amendment to the Constitution
does not entitle a defendant in a criminal trial to refuse to provide details of his alibi
witnesses to the prosecution, and that the Sixth Amendment
does not require a jury to have 12 members.
, and Florida law required him to notify the prosecution, in advance of the trial, of the names of his alibi witnesses, so that the prosecution could try to obtain rebuttal evidence. Williams argued that the requirement to assist the prosecution in this way violated his Fifth Amendment right not to incriminate himself.
Also, in 1967 Florida had reduced the number of jurors in all non-capital cases from 12 to 6, and so Williams had been convicted by a jury of six. Williams argued that the Sixth Amendment not only guaranteed the right to a jury trial, but also required that a jury must have all the characteristics it had under the common law
, including that it consist of 12 persons.
The Florida District Court of Appeal ruled against Williams on both issues. The Florida Supreme Court did not have jurisdiction to hear the case, and in 1969 the US Supreme Court agreed to hear the case.
to allow the prosecution to seek rebuttal evidence (this point was conceded by Williams's lawyers). Consequently, all the notice-of-alibi law did was allow the prosecution to do so before the trial, instead of having to interrupt the trial. It did not provide the prosecution with more information to use against a defendant than they would eventually get in any event.
The Court also held that the Sixth Amendment did not require a particular number of jurors. The point of a jury trial was to prevent oppression by the government:
This function of a jury could be performed just as well by six jurors as by twelve:
435 US 223 (1978) the Supreme Court held that a jury of 5 was unconstitutional.
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...
, argued on 4 March 1970 and decided on 22 June 1970. The Court held that the Fifth Amendment to the Constitution
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
does not entitle a defendant in a criminal trial to refuse to provide details of his alibi
Alibi
Alibi is a 1929 American crime film directed by Roland West. The screenplay was written by West and C. Gardner Sullivan, who adapted the 1927 Broadway stage play, Nightstick, written by Elaine Sterne Carrington, J.C...
witnesses to the prosecution, and that the Sixth Amendment
Sixth Amendment to the United States Constitution
The Sixth Amendment to the United States Constitution is the part of the United States Bill of Rights which sets forth rights related to criminal prosecutions...
does not require a jury to have 12 members.
Background
Williams had been convicted of robbery in Florida and sentenced to life imprisonment. Williams's defence had been alibiAlibi
Alibi is a 1929 American crime film directed by Roland West. The screenplay was written by West and C. Gardner Sullivan, who adapted the 1927 Broadway stage play, Nightstick, written by Elaine Sterne Carrington, J.C...
, and Florida law required him to notify the prosecution, in advance of the trial, of the names of his alibi witnesses, so that the prosecution could try to obtain rebuttal evidence. Williams argued that the requirement to assist the prosecution in this way violated his Fifth Amendment right not to incriminate himself.
Also, in 1967 Florida had reduced the number of jurors in all non-capital cases from 12 to 6, and so Williams had been convicted by a jury of six. Williams argued that the Sixth Amendment not only guaranteed the right to a jury trial, but also required that a jury must have all the characteristics it had under the common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
, including that it consist of 12 persons.
The Florida District Court of Appeal ruled against Williams on both issues. The Florida Supreme Court did not have jurisdiction to hear the case, and in 1969 the US Supreme Court agreed to hear the case.
Decision
The Court held that Florida's notice-of-alibi rule did not violate the Fifth Amendment. The Fifth Amendment would not be violated if, after the alibi witness had given evidence, the court granted a continuanceContinuance
In American procedural law, a continuance is the postponement of a hearing, trial, or other scheduled court proceeding at the request of either or both parties in the dispute, or by the judge sua sponte. In response to delays in bringing cases to trial, some states have adopted "fast-track" rules...
to allow the prosecution to seek rebuttal evidence (this point was conceded by Williams's lawyers). Consequently, all the notice-of-alibi law did was allow the prosecution to do so before the trial, instead of having to interrupt the trial. It did not provide the prosecution with more information to use against a defendant than they would eventually get in any event.
The Court also held that the Sixth Amendment did not require a particular number of jurors. The point of a jury trial was to prevent oppression by the government:
This function of a jury could be performed just as well by six jurors as by twelve:
Subsequent caselaw
In Ballew v. GeorgiaBallew v. Georgia
Ballew v. Georgia, 435 U.S. 223 , was a case heard by the United States Supreme Court that held that a Georgia state statute authorizing criminal conviction upon the unanimous vote of a jury of five was unconstitutional. The constitutional minimum size for a jury hearing petty criminal offenses...
435 US 223 (1978) the Supreme Court held that a jury of 5 was unconstitutional.
External links
- Full judgment from US Supreme Court Center