Chessman v. Teets

Background

A man convicted in Los Angeles in May 1948 was sentenced to death on two kidnapping-for-robbery counts. California law required an automatic appeal and preparation of the entire trial record. The official court reporter died after recording part of the trial; a substitute reporter was hired to transcribe the remaining pages, and the defendant later received the finished transcript and submitted about 200 corrections.

Reasoning

The Court considered whether the judge’s ex parte settlement of the transcript — held at hearings where the defendant was neither present nor represented by counsel — denied him the procedural due process guaranteed by the Fourteenth Amendment. The Court noted additional facts developed in later hearings: the substitute reporter had worked closely with the prosecutor and police, was related by marriage to the deputy district attorney, and had destroyed a rough draft. Even though a federal judge found no fraud, the Supreme Court held that the lack of an adversary proceeding or representation at the transcript settlement meant the state’s affirmance could not stand.

Real world impact

The Court vacated the lower federal rulings and remanded, directing the District Court to allow California a reasonable time to give the defendant a further review on a properly settled record; if California fails to do so, the defendant must be discharged. This decision requires that settlement of appellate trial records in capital cases meet basic fairness and representation requirements.

Dissents or concurrances

Two Justices dissented. One believed California had afforded due process. Another argued the defendant had ample opportunity to correct the record, failed to point to specific prejudicial errors, and that further proceedings were pointless after long delay.