Frank v. Mangum
"Frank v. Mangum" is a significant legal case involving Leo Frank, a Jewish factory manager accused of murdering a young girl in Georgia in 1913. The trial, which took place amidst a backdrop of intense anti-Semitism, has been widely criticized for its lack of due process, particularly as a mob threatened the jury during deliberations. Despite these irregularities, the federal district court denied Frank's request for a writ of habeas corpus, asserting that the federal government should not interfere in state criminal matters. The Supreme Court, in a 7-2 decision led by Justice Mahlon Pitney, upheld this stance.
This case highlights the complexities of federalism and the challenges faced in ensuring fair trials, especially in the context of societal prejudice. Years later, the Supreme Court recognized similar issues in a different case, "Moore v. Dempsey," which granted habeas corpus relief for defendants in mob-dominated trials. The contrasting decisions between "Frank v. Mangum" and later rulings underscore the evolving interpretations of justice and civil rights within the U.S. legal system. Leo Frank's case ultimately led to his lynching in 1915, marking a tragic episode in American history that reflects ongoing struggles against discrimination and the quest for legal equity.
Frank v. Mangum
Date: April 19, 1915
Citation: 237 U.S. 309
Issues: Trial by jury; habeas corpus
Significance: The Supreme Court refused federal relief for a defendant convicted of murder in state court under conditions of mob intimidation.
When Leo Frank, a Jewish capitalist, was tried in Georgia for the murder of a young woman, a large anti-Semitic mob intimidated the jury as it reached a guilty verdict. Almost all observers agreed that the trial did not conform to the due process requirements of the Fourteenth Amendment. Based on traditional notions of federalism, nevertheless, the federal district court rejected Frank’s petition for a writ of habeas corpus. Speaking for the 7-2 majority, Justice Mahlon Pitney upheld and defended the lower court’s hesitancy to intervene in a state criminal proceeding. Several years later, the Court in Moore v. Dempsey (1923) agreed to grant habeas corpus relief for defendants convicted in a similar mob-dominated trial. Justice Oliver Wendell Holmes dissented in Frank and wrote the majority opinion in Moore.
