Snyder v. Massachusetts

1934-01-08

Headline: Criminal defendant’s absence from a jury’s on-site view upheld; Court affirms conviction and allows states to exclude defendants from such views when no clear prejudice appears.

Holding: The Court affirmed the conviction, holding that excluding a defendant from a jury’s on-site view did not deny Fourteenth Amendment fair-procedure protections because no substantial prejudice to the defense was shown.

Real World Impact:

Allows courts to exclude defendants from crime-scene views absent clear prejudice.
Permits lawyers to point out scene features during jury views.
Leaves states discretion over on-site inspection procedures unless injustice appears.

Topics: fair trial rights, crime-scene view, defendant presence, jury evidence

Summary

Background

On April 9, 1931, a man was shot to death at a Somerville gasoline station. Three men were involved: one confessed and testified for the state, and two others, including the person who asked to attend a jury view, were tried together and sentenced to death. During trial a Massachusetts statute authorized the jury to visit the scene. The judge, the district attorney, court stenographer, and counsel went with the jury. The defendant asked to go with them but was denied. The jury was shown the station and surrounding streets, and counsel pointed out features. Photographs and a diagram were later placed in evidence and the defendant testified at trial.

Reasoning

The central question was whether excluding the defendant from that on-site view violated the Fourteenth Amendment’s guarantee of fair procedure. The Court assumed defendants have a constitutional right to be present when their presence substantially helps their defense, but it held that right does not extend to every situation. A bare inspection or a guided view that adds nothing the defendant could use is not necessarily a constitutional deprivation. Because the record showed the place was undisputed, photographs and diagrams were in evidence, and no reasonable possibility of prejudice appeared, the majority found no denial of due process. The Court noted one judicial mistake about a pump but treated it as harmless.

Real world impact

The ruling leaves states room to run jury views and to allow counsel to point out scene features without automatically requiring the defendant’s physical presence, so long as the absence does not reasonably risk injustice. It also signals that a defendant must show a real possibility of prejudice in the particular case to overturn such a practice.

Dissents or concurrances

A dissent argued the view was part of the trial evidence and that the defendant’s presence was essential to a fair hearing, so the dissent would have reversed the conviction.