The Vinson Court (1946–53)Introduction |
Did the Vinson Court rule that the right against self-incrimination protected state court defendants? |
No, the Vinson Court ruled in Adamson v. California (1947) that the Fifth Amendment’s privilege against self-incrimination was not extended to the states via the Fourteenth Amendment’s Due Process Clause. Dewey Adamson was charged with first-degree murder. At his trial, pursuant to California law, the prosecutor pointed out to the jury that Adamson had refused to testify in his own defense. Adamson contended on appeal that his conviction should be invalidated because the prosecution violated his privilege against self-incrimination by asking the jury to consider the fact that he did not testify in his own defense. The majority rejected Adamson’s arguments, reasoning that “the Due Process Clause does not protect, by virtue of its mere existence the accused’s freedom from giving testimony by compulsion in state trials that is secured to him against federal interference by the Fifth Amendment.” The majority relied on precedent for the principle that the Fourteenth Amendment “does not draw all the rights of the federal Bill of Rights under its protection.”
The U.S. Supreme Court reversed the Adamson decision and applied the Fifth Amendment Clause against self-incrimination to the states in Griffin v. California (1965).