Mallory v. United States
**Overview of Mallory v. United States**
Mallory v. United States is a significant Supreme Court case that builds upon the earlier decision in McNabb v. United States, focusing on the rights of defendants within the federal criminal justice system. The Court, led by Justice Felix Frankfurter, upheld the McNabb rule, which protects defendants from having statements made during improper detention used against them in trial. While this ruling reinforced individual rights in federal cases, it did not extend the same protections to state criminal cases, highlighting the limitations of the Fourteenth Amendment's incorporation doctrine. This distinction is crucial as it emphasizes the federal government's ability to establish rules for federal courts, while state courts remain governed by different standards. The Court's decision indicated a reluctance to universally apply the McNabb rule at the state level, ultimately preferring to rely on future cases, such as Miranda v. Arizona, to address similar issues. Over time, the McNabb rule was effectively phased out, illustrating the evolving nature of legal protections for defendants. This case reflects ongoing discussions about civil rights, due process, and the balance between law enforcement interests and individual liberties in the American legal landscape.
Mallory v. United States
Date: June 24, 1957
Citation: 354 U.S. 449
Issue: Defendants’ rights
Significance: The Supreme Court reaffirmed its power to create rules of evidence that apply in federal criminal cases.
In McNabb v. United States (1943), the Supreme Court ruled that any statements an accused made while being improperly detained could not be used against that person at trial, thereby dramatically reducing the prospect of coerced confessions. In Mallory, Justice Felix Frankfurter wrote the unanimous opinion for the Court sustaining the McNabb rule for use in federal criminal cases but not extending the rule to state criminal cases under the incorporation doctrine of the Fourteenth Amendment. The Court can only set aside state criminal convictions for violation of the Fourteenth Amendment’s due process clause, but it can directly create rules for the federal courts. At one point, it seemed the Court might apply the McNabb rule to the states through the Fourteenth Amendment incorporation doctrine, but the Court chose to rely instead on the Miranda v. Arizona (1966) rule to achieve the comparable purpose. The McNabb rule was not constitutional law, so it could be changed by congressional action. It was effectively eliminated in the late 1960’s.
