Karin has taught middle and high school Health and has a master's degree in social work.
What Is Williams v. Florida?
Williams v. Florida, 399 U.S. 78, in 1970, was a U.S. Supreme Court case that determined that the Fifth Amendment did not excuse a criminal defendant from having to disclose his alibi witnesses before trial; it also concluded that the Sixth Amendment did not require that his jury be 12 people. Let's take a quick look at the fifth and sixth amendments before learning about the case.
Overview of the Fifth and Sixth Amendments
The Fifth Amendment of the U.S. Constitution was created to protect the rights of criminals or trial defendants, guilty or not. Williams was convicted of burglary. When he was asked to reveal his alibi witnesses before trial, he felt like he was being coerced to incriminate himself because this would be assisting the prosecution in arranging rebuttal evidence against his alibi(s).
There is a clause in the fifth amendment that safeguards individuals from being forced to implicate or incriminate themselves. This is why an individual can refuse to answer questions posed by a police officer (often until they have a lawyer present) if the answer could possibly expose their guilt. Williams was arguing that providing his alibi witnesses before trial was in violation of his fifth amendment rights.
The Sixth Amendment of the U.S. Constitution was created to protect an individual's rights to have a relatively speedy public trial, a lawyer, a jury, knowledge of who the accusers are, and comprehension of the nature of the crime that he committed. Have you ever seen the 1957 film, Twelve Angry Men? Many people, including Williams, envision a jury to be 12 people. When Williams noticed that his jury was only 6 people, he felt like his sixth amendment rights were being violated.
Overview of the Case
After being convicted of burglary, Williams was tried in Florida state court. As stated above, he refused to provide his alibi witnesses to the court pretrial because he felt it was violating his fifth amendment rights. An alibi witness is a person that proves a criminal defendant was elsewhere at the time the crime was committed, and therefore would not have been able to commit the crime. He also thought that the 6-person jury, instead of 12, was violating his sixth amendment rights. He motioned for a protective order with the Supreme Court.
Conclusions of the Case
Williams did not win the case in either of his motions for protective order. In fact, Williams was eventually convicted of the burglary charge and given a life sentence. The Supreme Court overruled Williams's motion for a protective order and required him to provide his alibi, which was a friend named Mary Scotty. Her story was inconsistent from pretrial to trial and she reported that she was with Williams when she was actually being questioned by police.
The Supreme Court concluded that if a person does not provide his alibi(s) pretrial, he cannot use them in trial. The reason is that if alibi witnesses were only presented in trial, there would not be enough time for the prosecution to fully research whether or not these witnesses were valid.
Despite Williams's insistence on having a 12-person jury, the Supreme Court ruled that there was no stipulation in the Sixth Amendment of the Constitution requiring this. Although a 12-person jury would probably be more diverse and representative of the population, a 6-person jury was ruled constitutional, and even more efficient. From this point forward, Florida began using a six-person jury for most criminal cases, except for capital, or death penalty cases, where they use a 12-person jury.
There were a few raised eyebrows in one of the biggest cases in Florida in the 21st century, the George Zimmerman case, where he was acquitted of murdering a teenager, Trayvon Martin, due to Zimmerman's plea that he killed him out of self-defense. Many were questioning why there were only six jurors in the courtroom for this case. Williams v. Florida is the reason.
Williams v. Florida, in 1970, was a U.S. Supreme Court case that determined that the Fifth Amendment did not excuse a criminal defendant from having to disclose his alibi witnesses before trial; it also concluded that the Sixth Amendment did not require that the jury be 12 people. Williams was accused of burglary and held to trial. He felt his Fifth Amendment rights were being violated when asked to provide his alibis pretrial, and that his Sixth Amendment rights were being violated when his jury was only six people. His motion for protective order by the Supreme Court was overruled and he was sentenced to a life sentence in prison.
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