## Facts

- Leon Chambers was tried in Mississippi for murdering Police Officer Aaron Liberty and consistently denied being the shooter.
- Another man, Gable McDonald, gave a sworn written confession admitting he shot Liberty and separately made three oral confessions to three different acquaintances.
- At a preliminary hearing, McDonald repudiated the written confession.
- At trial, Chambers called McDonald and introduced the written confession; the State elicited that McDonald had withdrawn it.
- The trial court applied Mississippi’s “voucher” rule to prevent Chambers from treating McDonald as adverse and cross-examining him about his prior confessions and repudiation.
- The trial court excluded, as hearsay, testimony from the three acquaintances recounting McDonald’s oral confessions, even though McDonald was present and available.
- Chambers was convicted of murder and sentenced to life imprisonment; the Mississippi Supreme Court affirmed.

## Issues

1. Whether applying the voucher rule to bar Chambers from cross-examining McDonald about prior confessions and repudiation denied due process.
2. Whether excluding as hearsay testimony about McDonald’s repeated confessions—offered as exculpatory evidence with strong reliability markers—denied due process by preventing Chambers from presenting a defense.

## Decision

- The Supreme Court reversed and remanded, holding that Chambers was denied a fair trial under the Fourteenth Amendment’s Due Process Clause.
- The Court held that, as applied, the voucher rule improperly blocked effective cross-examination of a witness whose testimony was adverse to the defense.
- The Court held that excluding the three witnesses’ testimony about McDonald’s confessions, which carried persuasive assurances of trustworthiness and was critical to the defense, compounded the unfairness.
- The Court emphasized the ruling was based on the combined effect of the evidentiary restrictions in the particular circumstances, not a categorical invalidation of voucher or hearsay rules.

## Legal Principles

- Due process is violated when state evidentiary rules are applied so rigidly that they prevent a criminal defendant from presenting reliable, exculpatory evidence central to the defense.
- Effective cross-examination is a fundamental component of a fair trial; a defendant must have a meaningful opportunity to challenge adverse testimony.
- Hearsay rules serve legitimate purposes but may not be applied mechanically to exclude trustworthy, critical exculpatory evidence, especially where the declarant is available for cross-examination.
- Reliability factors supporting admission of third-party confessions include spontaneity to close acquaintances, corroboration, statements against penal interest, and the declarant’s availability at trial.

## Conclusion

The Court held that Mississippi’s combined use of the voucher rule and hearsay exclusion prevented Chambers from effectively testing McDonald’s shifting account and from presenting trustworthy third-party confessions, rendering the trial fundamentally unfair in violation of due process.


Chambers v. Mississippi, 410 U.S. 284 (1973)