Facts
- Jackie Washington, age 18, was tried in Dallas County, Texas, for murder with malice and sentenced to 50 years.
- The prosecution’s evidence linked Washington and Charles Fuller to a fatal shotgun blast fired outside Jean Carter’s home after bricks were thrown at the house.
- Washington testified that Fuller, allegedly drunk, insisted on shooting someone; Washington claimed he ran back to the car before the shot.
- Washington attempted to call Fuller as a defense witness.
- The trial court excluded Fuller solely under Texas statutes that disqualified persons charged as principals, accomplices, or accessories in the same crime from testifying for one another, while permitting them to testify for the State.
- The record indicated Fuller would have testified that Washington tried to persuade Fuller to leave and that Washington ran before Fuller fired; the testimony was undisputedly relevant, material, and vital to the defense.
- The Texas Court of Criminal Appeals affirmed; the U.S. Supreme Court granted certiorari.
Issues
- Whether the Sixth Amendment right to compulsory process for obtaining witnesses in the defendant’s favor applies to the States through the Fourteenth Amendment.
- Whether Texas violated that right by enforcing statutes that barred a charged participant from testifying for a co-participant while allowing testimony for the prosecution.
Decision
- The Supreme Court reversed.
- The Court held that the Sixth Amendment compulsory process right is fundamental and applies to the States through the Fourteenth Amendment’s Due Process Clause.
- The Court held the Texas statutes unconstitutionally and arbitrarily denied Washington the ability to present a relevant and material defense witness.
Legal Principles
- A criminal defendant has a constitutional right to offer the testimony of witnesses and to compel their attendance when necessary; this is part of the right to present a defense.
- The Sixth Amendment Compulsory Process Clause is incorporated against the States via the Fourteenth Amendment.
- A State may not use categorical witness-disqualification rules that arbitrarily exclude defense testimony that is relevant and material.
- States retain latitude to apply ordinary evidentiary rules (e.g., excluding repetitive, marginally relevant, or prejudicial evidence), but exclusions must be justified by legitimate trial interests rather than a priori distrust of whole categories of defense witnesses.
Conclusion
The Court held that the compulsory process right applies to state prosecutions and that Texas violated due process by enforcing a categorical rule that prevented Washington from presenting vital, material testimony from an alleged accomplice solely because the witness was charged in the same offense.