Moore v. Dempsey
Moore v. Dempsey is a landmark Supreme Court case stemming from the 1919 racial violence in Phillips County, Arkansas, known as the Elaine Race Riot, which led to the deaths of numerous African Americans and resulted in the prosecution of over one hundred Black individuals, while no white individuals faced similar charges. The case arose when six defendants, sentenced to death under highly charged and mob-influenced conditions, sought a federal habeas corpus hearing after their convictions. Initially, the district court dismissed their petition, citing earlier precedents that limited federal intervention in state court rulings influenced by mob violence. However, the Supreme Court, in a 6-2 decision, reversed this dismissal, emphasizing that trials affected by mob threats fundamentally violate constitutional due process rights. Justice Oliver Wendell Holmes highlighted the duty of state courts to ensure fair trials and affirmed the federal court's responsibility to intervene when there is evidence of such a failure. The dissenting opinions expressed concern over potential federal overreach into state judicial processes. This case is significant in the discourse on civil rights and the intersection of state and federal judicial authority, particularly regarding the protection of defendants' rights in racially charged environments.
Moore v. Dempsey
Date: February 19, 1923
Citation: 261 U.S. 86
Issues: Trial by jury; habeas corpus
Significance: The landmark Moore decision marked two constitutional developments: the Supreme Court’s actual utilization of the due process clause of the Fourteenth Amendment as a limitation on state criminal proceedings and the federal courts’ supervision of state proceedings by way of habeas corpus petitions.
In 1919 a violent racial clash in Phillips County, Arkansas, resulted in the deaths of scores of African Americans and five whites. More than one hundred African Americans, and no whites, were prosecuted. Swift trials took place in a lynch-mob atmosphere, with large angry crowds intimidating the juries.
Six defendants sentenced to death petitioned the federal district court for a habeas corpus hearing. As recently as Frank v. Mangum (1915), however, the Supreme Court had refused federal relief for a defendant convicted of murder in state court under mob-influenced conditions similar to those of Phillips County. Therefore, the district court dismissed the petition.
By a 6-2 vote, the Supreme Court reversed the ruling and instructed the lower court to hold a habeas corpus hearing. Speaking for the Court, Justice Oliver Wendell Holmes observed that a trial influenced by the threat of mob violence was manifestly inconsistent with the constitutional requirements for due process of law. The state courts had the obligation to guarantee fair trials for the defendants, but if evidence indicated a failure to meet this obligation, the federal courts then had the duty to review the record and determine whether the convictions should be overturned. The two dissenters expressed concern that the ruling would result in excessive federal interference in state proceedings.