## Facts

- Frank Moore and other Black defendants were convicted of first-degree murder in Phillips County, Arkansas, and sentenced to death following events associated with the 1919 Elaine violence.
- The prosecutions occurred in a racially charged environment marked by mass arrests of Black residents and allegations of violence and coercion used to obtain statements.
- Petitioners alleged their state trials were conducted with all-white juries and were dominated by mob pressure, rendering counsel, judge, and jury unable to provide a fair adjudication.
- Petitioners further alleged the state relied on coerced testimony and confessions extracted through threats and physical abuse.
- After state appellate and postconviction efforts failed to provide relief, petitioners sought federal habeas corpus in the U.S. District Court for the Eastern District of Arkansas.
- The district court dismissed the federal habeas petition on demurrer, without taking evidence, treating the alleged facts as legally insufficient.

## Issues

1. Whether federal courts on habeas corpus may look beyond the formal regularity of state criminal proceedings to assess allegations that a trial was a mob-dominated sham violating Fourteenth Amendment due process.
2. Whether a federal district court may dismiss, without an evidentiary hearing, a habeas petition alleging that state convictions were obtained through mob domination and coerced testimony where state corrective processes did not effectively remedy the alleged wrong.

## Decision

- The Supreme Court reversed the district court’s dismissal and remanded.
- Because the case was dismissed on demurrer, the Court treated the petition’s factual allegations as true for purposes of review.
- The Court held that a murder conviction obtained through a mob-dominated trial “without regard for [defendants’] rights” is “without due process of law and absolutely void.”
- The Court concluded that where state processes have not provided an effective correction, the federal district court must determine the truth of the mob-domination allegations and whether any explanation permits leaving the state judgment undisturbed.

## Legal Principles

- A state conviction produced by a trial hurried to judgment under mob domination, such that the proceeding is effectively a sham, violates the Due Process Clause of the Fourteenth Amendment and is void.
- On appeal from dismissal of a habeas petition on demurrer, the habeas court must accept the petition’s well-pleaded factual allegations as true.
- Federal habeas review is not confined to facial regularity when the petitioner alleges facts showing a fundamentally unfair state trial and the state’s corrective process was insufficient in practice.
- In such circumstances, a federal district court must hold an evidentiary inquiry to determine the truth and effect of the alleged constitutional defects.

## Conclusion

Moore v. Dempsey required federal habeas courts to conduct fact-finding when condemned state prisoners plausibly allege that mob domination and related coercion made the trial a due process nullity and state review failed to correct the violation.


Moore v. Dempsey, 261 U.S. 86 (1923)