Four Supreme Court Cases on Protest and Criminal Procedure

Edwards v. South Carolina (1963): Protected Peaceful Assembly at the Capitol

Edwards v. South Carolina is based upon an event that occurred on March 2, 1961. On that date, 187 people peacefully marched upon the state capital of South Carolina to voice their grievances about the inequalities facing African Americans. After being ordered to disperse, they were arrested under the charge of breach of the peace. They sued the state, claiming that the arrest violated their First and Fourteenth Amendment rights. The evidence showed that there was no threat of violence directed at public safety or the officers involved. Instead, the protestors sang patriotic and religious songs in unison.

The main issue was whether the state has the right to enforce breach-of-peace laws when someone is peacefully demonstrating. Additionally, the Court considered whether citizens have the right to publicly assemble in order to highlight their views to elected officials.

The U.S. Supreme Court found that the state of South Carolina was in violation of the First and Fourteenth Amendments. The law infringed upon the protestors' rights to peacefully bring grievances to elected officials. Under the Fourteenth Amendment, the state cannot punish someone for these actions, as this clause protects these freedoms against state laws that are enforced.

The ruling was based on the fact that no one posed a threat to public safety and the demonstrators were simply singing songs. The peaceful nature of the assembly, combined with its location at the seat of government where petitions are properly directed, led the Court to conclude that First Amendment protections applied.

Justice Clark wrote the dissenting opinion, arguing that the state has the right to establish laws protecting public safety. He believed these laws are designed to control when someone is allowed to protest and assemble, and that South Carolina's breach-of-peace statute served a legitimate state interest.

Adderley v. Florida involved 30 students who were arrested for demonstrating against racial segregation at a Florida county jail in 1966. They were clapping, singing, and dancing after the sheriff advised them that they were trespassing on public property and preventing the operation of the facility.

Adderley v. Florida (1966): Limits on Protest at Government Facilities

The main issue was whether protestors have the right to assemble and voice their grievances in front of any public building or facility, specifically a detention center.

In a 5 to 4 decision, the Supreme Court upheld the arrests.

The Court reasoned that detention centers and jails are not public places in the traditional sense where First Amendment assembly rights apply. Therefore, protesting upon jail grounds was not infringing upon the demonstrators' right to assembly, as they lacked a general right to protest at any government facility.

The dissenting justices did not believe that these individuals were intending any kind of violence directed at the facility or blocking the entrance. They argued that public officials do not have the right to decide which facilities are subject to First Amendment protections based upon the facility's classification or function.

The facts of U.S. v. Wise began in 1997 and extended into 1998. Members of the militia group the Republic of Texas were planning on sending biological agents to different government officials as a way to show that they had declared war on the federal government. The FBI conducted an investigation using a confidential informant who provided detailed information about the group's activities.

U.S. v. Wise (2000): Evidentiary Standards and Informant Testimony

The main issue was whether the FBI had enough information to convict two of the men involved in the plot based upon the testimony of a confidential informant.

The Fifth Circuit Appellate Court found that the testimony was not enough to convict these individuals beyond a reasonable doubt. The primary evidence against them was hearsay and could have easily been taken out of context.

The ruling is based on the fact that there was no corroborating evidence provided to show that the defendants were clearly involved in these activities. Instead, the government was relying mainly on the testimony of a confidential informant. The court believed that the informant played a part in influencing these individuals to become part of the larger plot. Moreover, the prosecutors' conduct during the case brought into question whether these men had received a fair trial. This concern arose through improper remarks made to the jury in the closing statements.

There were no dissenting opinions in this case; the decision was unanimous among the judges.

In U.S. v. Bailey, three criminal inmates were charged with escaping from the District of Columbia jail in 1978. They challenged the ruling, alleging that the conditions were so horrible that they could not return to the location, as it would subject them to cruel and unusual punishment.

U.S. v. Bailey (1980): Inmate Rights and Conditions of Confinement

The main issue was whether inmates have the right to challenge their detention when they knowingly escape from custody. Additionally, the Court considered whether the conditions in the jail were reason enough for them to break the law.

The U.S. Supreme Court ruled in favor of the federal government.

The defense could not show adequate proof that the alleged conditions actually existed. Moreover, the inmates failed to demonstrate how their inability to turn themselves in was the primary factor affecting their decisions when they were on the run from the law. The Court found that the duress defense requires showing that conditions left no reasonable opportunity to escape or turn oneself in.

Two dissenting opinions were filed by Justices Blackmun and Brennan. They believed that inmates had a right to question facility conditions and that the actions taken were in defense of their constitutional rights against cruel and unusual punishment.