Malloy v. Hogan
Malloy v. Hogan is a significant Supreme Court case that took place in 1964, focusing on the application of the Fifth Amendment’s protection against self-incrimination at the state level. In a narrow 5-4 decision, the Court reversed a contempt citation against an individual who chose not to testify in a state court, marking a pivotal shift in the interpretation of the Fourteenth Amendment's incorporation doctrine. This ruling established that states must adhere to the same standards of due process as the federal government, moving beyond the previous requirement of merely achieving fundamental fairness. The decision has been viewed as a precursor to the later landmark case Miranda v. Arizona, which further extended protections against self-incrimination. The ruling was not without dissent; some justices expressed concern that the facts of the Malloy case did not warrant the application of the privilege against self-incrimination. Overall, Malloy v. Hogan played a crucial role in shaping the landscape of individual rights within the American legal system, emphasizing the importance of protecting individuals from self-incrimination in state proceedings.
Malloy v. Hogan
Date: June 15, 1964
Citation: 378 U.S. 1
Issue: Immunity against self-incrimination
Significance: The Supreme Court’s decision established that the Fifth Amendment’s protection against self-incrimination applied to the states.
Justice William J. Brennan, Jr., wrote the 5-4 majority opinion for the Supreme Court, reversing a contempt citation of a person who declined to testify in a state court. The Court’s ruling applied the Fifth Amendment protection against self-incrimination to the states under the Fourteenth Amendment’s incorporation doctrine. The Court thus reversed a long-standing position that states needed only to achieve fundamental fairness, not strict adherence to the exact terms of the Bill of Rights, to provide due process as required by the Fourteenth Amendment. Although the case did not involve a confession, the decision does appear to be a forerunner of the Miranda v. Arizona (1966) decision. Justices Tom C. Clark and John M. Harlan II rejected the majority’s application of the privilege to defendants in state proceedings. Justices Potter Stewart and Byron R. White agreed with the majority that the privilege against self-incrimination applied to the states but dissented because they did not feel that the facts of this case fit the privilege.
