Adamson v. California
Adamson v. California is a significant Supreme Court case addressing the rights of defendants, particularly in relation to self-incrimination and the implications of a prior criminal record. In this case, Admiral D. Adamson was tried for murder and chose not to testify, a decision influenced by his past criminal history. The prosecution argued that Adamson's refusal to testify could be inferred as evidence of guilt, a practice previously sanctioned by the Court. Adamson's legal team contended this practice violated his Fifth Amendment rights. Ultimately, the Supreme Court upheld Adamson's conviction, emphasizing that the Fourteenth Amendment did not necessitate states to apply all protections of the Bill of Rights uniformly. Justice Hugo L. Black's dissent was particularly notable, advocating for the "total incorporation" of the Bill of Rights into the Fourteenth Amendment, a perspective not adopted by the majority. However, this case laid the groundwork for future rulings, leading to the eventual incorporation of the privilege against self-incrimination at the state level. Overall, Adamson v. California highlights the ongoing debates surrounding due process and the application of constitutional protections in the American legal system.
Subject Terms
Adamson v. California
Date: June 23, 1947
Citation: 332 U.S. 46
Issue: Incorporation doctrine
Significance: Reaffirming that the Fifth Amendment privilege against self-incrimination was not applicable to the states, the Supreme Court reiterated that the due process clause of the Fourteenth Amendment incorporated only those procedural rights considered essential to a fair trial.
When tried for murder, Admiral D. Adamson did not testify, because of his prior criminal record. The district attorney, as permitted by applicable state law at the time, told the jury that Adamson’s refusal to testify was a good reason to infer his guilt. The Supreme Court had earlier permitted this practice in Twining v. New Jersey (1908). After Adamson was convicted, his attorney argued that permitting the prosecutorial comment was a violation of the Fifth Amendment. A 5-4 majority of the Court upheld the conviction, based on the long-standing doctrine that the Fourteenth Amendment did not require the states to honor all the privileges and protections of the Bill of Rights.
Adamson is notable primarily because of Hugo L. Black’s long dissent, which used historical data to argue for the “total incorporation” of the entire Bill of Rights into the Fourteenth Amendment. Justice Felix Frankfurter’s concurring opinion defended the alternative theory of “selective incorporation.” Although subsequent Courts have never accepted Black’s perspective, the privilege against self-incrimination was made binding on the states in Malloy v. Hogan (1964). This privilege was interpreted to prohibit prosecutorial comment on a defendant’s failure to testify in Griffin v. California (1965).