How a Florida murder and an unlikely justice created a 'criminal procedure revolution'
U.S. Supreme Court Justice Hugo L. Black wrote the opinion in Chambers v. Florida three years after he joined the court in 1937. His nomination became controversial after his former membership in the Ku Klux Klan came to light. (Photo by the Library of Congress/Corbis/VCG via Getty Images)
In Chambers v. Florida and the Criminal Justice Revolution, historian and former ABA Journal editor Richard Brust lifts the veil on a case that laid the groundwork for some much more famous civil rights victories.
On May 13, 1933, shopkeeper Robert Darsey was robbed and murdered in Pompano, Florida. Four Black migrant farm workers—Izell Chambers, Walter Woodard, Jack Williamson and Charlie Davis—were seized and pressured by the local sheriff into confessing to the murder under threat of lynching. Their appeals eventually reached the U.S. Supreme Court through the efforts of some dedicated African American attorneys and succeeded in 1940.
In Justice Hugo L. Black’s written opinion for the majority, the justice drew parallels between the Jim Crow regime in the American South and the rise of authoritarianism and fascism in Europe. Chambers v. Florida forbade the use of psychological coercion—such as threatening to turn prisoners over to lynch mobs—as well as physical abuse as methods for extracting confessions. The court’s ruling declared that the protections of the Bill of Rights extended into states’ criminal cases and began to change the kinds of cases that made it onto the Supreme Court docket.
Brust sees it as part of a trio of cases, which includes Moore v. Dempsey (1923) and Brown v. Mississippi (1936), that led to a “criminal procedure revolution,” he tells the ABA Journal’s Lee Rawles.
In this episode of The Modern Law Library podcast, Brust discusses the lawyers who worked on the case, most prominently Simuel D. McGill, a Black attorney in Jacksonville, Florida. He delves into the generational differences between the Floridian defense lawyers and the attorneys of the NAACP’s Legal Defense Fund who would go on to win key civil rights battles. He explains why Black would have been considered an unlikely author for this opinion. And he shares what he could discover about the fates of Chambers, Woodard, Williamson and Davis after the trial.
In This Podcast:
Richard Brust
Richard Brust was assistant managing editor at the ABA Journal from 1997 to 2015. He supervised the National Pulse and Supreme Court sections and wrote features on topics in legal history. Brust is an award-winning writer and editor and has a law degree from Temple University. He recently was awarded a PhD in history from the University of Florida.
