Miller v. Pate, 386 U.S. 1 (1967)

Facts

  • An eight-year-old girl in Canton, Illinois died after a sexual assault; Lloyd Eldon Miller, Jr. was prosecuted for murder and sentenced to death.
  • The case was circumstantial and had no eyewitnesses.
  • A key exhibit was a pair of men’s underwear (“People’s Exhibit 3”) found about a mile from the crime scene; the State argued Miller wore and discarded it.
  • At trial, the State repeatedly characterized the garment as “bloody shorts” and presented it as linking Miller to the crime.
  • A state chemist testified the stains were blood, typed as group A (matching the victim), while other evidence showed Miller’s blood type was O.
  • In later federal habeas proceedings, chemical testing showed the stains were paint pigment with no blood present.
  • The record established that state officials knew at the time of trial that the stains were paint, yet the prosecution presented them as blood through deliberate misrepresentations.

Issues

  1. Whether the Due Process Clause permits a conviction obtained through the State’s knowing use of false evidence and deliberate misrepresentation of material physical evidence.

Decision

  • The Supreme Court reversed the court of appeals and remanded.
  • The Court held that the Fourteenth Amendment does not permit a conviction secured by the knowing use of false evidence.
  • The prosecution’s deliberate misrepresentation that paint stains were blood stains rendered the trial constitutionally invalid.

Legal Principles

  • Due process is denied when the State knowingly uses false evidence to obtain a conviction.
  • The constitutional violation includes deliberate prosecutorial misrepresentations about material physical evidence, not only perjured testimony.
  • A conviction obtained through intentional deception of the court and jury is incompatible with a fair trial under the Fourteenth Amendment.

Conclusion

The Court set aside Miller’s conviction because state officials knowingly presented materially false “blood” evidence to the jury, and due process forbids convictions obtained by deliberate prosecutorial deception.