Significance: In this case, the Supreme Court extended the influence of the equal protection clause of the Fourteenth Amendment in the area of justice and the rights of accused criminals. The Court also guaranteed legal protections to all Americans who might be tried and convicted in courts influenced by mobs.
Background: On September 30, 1919, in Phillips County, Arkansas, a group of white men attacked some African Americans gathered at a church. One white man was killed during the attack. A racial clash followed in which about two hundred African Americans and five white people died. Six African Americans, including Frank Moore, were charged with the murder of Clinton Lee during the incident. At the trial, the defendants’ attorney offered no defense. The trial lasted forty-five minutes and the jury returned in less than five minutes with a guilty verdict. Moore and the other defendants petitioned for a habeas corpus hearing to determine the legality of their conviction. They sued E. H. Dempsey, the keeper of the Arkansas State Penitentiary. The defendants claimed that a mob of white people wanting to lynch them influenced the outcome of the trial and that witnesses had been tortured to give testimony. The federal district court dismissed the petition without a hearing. The National Association for the Advancement of Colored People (NAACP) appealed the case to the Supreme Court.
Decision: This case was argued on January 9, 1923, and decided on February 19, 1923, by a vote of 6 to 2. Justice Oliver Wendell Holmes spoke for the Court. Justices James McReynolds and George Sutherland dissented. Justice John Clarke did not participate. The majority overruled the federal court. Holmes argued that if the claims were true, then the trial violated the equal protection clause of the Fourteenth Amendment. The Court further ruled that it had a duty to review state trials and release defendants convicted in mob-dominated trials.
Excerpt from the Opinion of the Court: “We shall not say more concerning the corrective process afforded to the petitioners than that it does not seem to us sufficient to allow a Judge of the United States to escape the duty of examining the facts for himself when if true as alleged they make the trial absolutely void. . . . It appears to us unavoidable that the District Judge should find whether the facts alleged are true and whether they can be explained so far as to leave the state proceedings undisturbed.”
