Facts
- Florida adopted Canon 3A(7) of its Code of Judicial Conduct after a pilot program, permitting electronic media and still photography coverage of judicial proceedings under trial-court control and implementing guidelines aimed at protecting fair-trial rights.
- Noel Chandler and Robert Granger, Miami Beach police officers, were tried for burglary of a local restaurant.
- Portions of their criminal trial were televised pursuant to Canon 3A(7).
- The defendants objected, arguing that televised coverage denied them a fair and impartial trial.
- A jury convicted both defendants.
- The Florida District Court of Appeal affirmed, finding no evidence that cameras hampered the defense, deprived defendants of an impartial jury, or impaired trial fairness.
- The Florida Supreme Court denied review, and the defendants sought review in the U.S. Supreme Court.
Issues
- Whether permitting radio, television, and still photographic coverage of a state criminal trial for public broadcast violates the Sixth Amendment right to a fair trial, as applied to the states through the Fourteenth Amendment Due Process Clause.
- Whether prior precedent established a per se constitutional rule barring televised coverage of criminal trials.
Decision
- Affirmed (8–0; Justice Stevens not participating).
- The Constitution does not prohibit a state from authorizing televised and photographic coverage of criminal trials under a regulated program like Florida’s Canon 3A(7).
- The Court rejected the claim that prior precedent created an absolute constitutional ban on broadcast coverage of criminal proceedings.
- Absent a showing that media coverage actually compromised the fairness of the particular trial, allowing cameras in the courtroom did not violate due process.
Legal Principles
- The Supreme Court lacks general supervisory authority over state courts; its review is limited to whether state procedures violate the Federal Constitution.
- Due process does not impose a categorical prohibition on photographic, radio, or television coverage of criminal trials.
- A defendant challenging courtroom broadcasting must show case-specific prejudice—i.e., that media coverage compromised the particular jury’s ability to decide guilt or innocence fairly.
- Potential risks associated with broadcasting do not, by themselves, justify a constitutional rule forbidding televised trials in all circumstances.
- State rules allowing electronic coverage may be constitutional when they place proceedings under the trial judge’s control and include safeguards to protect fair-trial rights, including protection for certain witnesses and consideration of defense objections.
Conclusion
The Court held that states may allow broadcast and photographic coverage of criminal trials under judicial control and protective guidelines, and that a defendant must demonstrate actual, trial-specific prejudice to establish a constitutional violation of the right to a fair trial.