Twining v. New Jersey

211 U.S. 78 (1908)

Quick Summary

Twining and Cornell (defendants) were convicted of fraud in New Jersey (plaintiff), with their refusal to testify used as an inference of guilt. They challenged this on constitutional grounds, asserting a violation of their Fourteenth Amendment rights.

The Supreme Court evaluated whether such protection from self-incrimination applied against state actions. Ultimately, it was decided that this right is not protected under the ‘privileges or immunities’ clause of the Fourteenth Amendment regarding state laws.

Facts of the Case

Albert C. Twining and David C. Cornell (defendants) were accused of fraudulent actions within the state of New Jersey (plaintiff). The New Jersey statute that allowed juries to infer guilt from a defendant’s silence if they chose not to testify in their own defense.

When Twining and Cornell were convicted under this law, they challenged the conviction, arguing that the statute violated their Fourteenth Amendment rights.

Procedural Posture and History

  1. Twining and Cornell were charged with fraud and subsequently convicted in a New Jersey state court.
  2. The defendants appealed their conviction, challenging the New Jersey law that permitted juries to draw negative inferences from a defendant’s silence.
  3. The appeal was based on the assertion that such a law was unconstitutional under the Fourteenth Amendment.
  4. The case was appealed to the Supreme Court of the United States.

I.R.A.C. Format

Issue

  • Whether a state law permitting juries to infer guilt from a defendant’s refusal to testify violates the Fourteenth Amendment’s protections against self-incrimination.
  • Whether such protection is applicable against state action.

Rule of Law

The Fourteenth Amendment limits state powers and restrains their exercise, including laws that violate fundamental rights. However, privileges and immunities of United States citizenship, as protected by the Fourteenth Amendment, are distinct from those protected by state citizenship. The exemption from self-incrimination, although a fundamental right, is traditionally considered a privilege of state citizenship, protected solely by state governments. The Fourteenth Amendment does not extend the protections of the first eight Amendments to the states unless those rights are deemed fundamental to due process of law.

Reasoning and Analysis

The defendants argued that the exemption from self-incrimination should be protected under the Fourteenth Amendment, either as a privilege of United States citizenship or as part of due process of law. However, historical precedent and judicial interpretation suggest otherwise. The Supreme Court, in the Slaughter-House Cases, established that privileges and immunities of United States citizenship are distinct from those of state citizenship. Furthermore, rights enumerated in the first eight Amendments are not automatically protected against state action unless they are fundamental to due process of law.

They concluded that while the right against self-incrimination is indeed fundamental, it is a privilege of state citizenship rather than national citizenship, and thus not within the scope of ‘privileges or immunities’ protected by the Fourteenth Amendment. Furthermore, they determined that specific personal rights enumerated in the first eight Amendments to the Constitution did not constitute ‘privileges or immunities’ under the Fourteenth Amendment when it comes to state action.

Conclusion

The Court held that the exemption from compulsory self-incrimination is not a privilege or immunity of national citizenship under the Fourteenth Amendment and thus cannot be invoked against state action. Consequently, the New Jersey law allowing negative inferences from a defendant’s silence did not violate Twining and Cornell’s constitutional rights. Therefore, the defendants’ challenge is not upheld.

Key Takeaways

  1. The right against compulsory self-incrimination is considered fundamental but is not protected against state action by the Fourteenth Amendment.
  2. Only privileges or immunities arising out of national citizenship or those specifically granted by the Constitution are protected against state encroachment under the Fourteenth Amendment.
  3. Personal rights enumerated in the first eight Amendments to the Constitution are not automatically applicable to states under the Fourteenth Amendment’s privileges or immunities clause.

Relevant FAQs of this case

What is the significance of the Privileges or Immunities Clause in relation to state laws?

The Privileges or Immunities Clause, found in the Fourteenth Amendment, establishes that certain rights inherent to national citizenship cannot be abridged by state governments. However, it does not guarantee that all rights afforded by the federal constitution are protected at state level.

  • For example: The right to travel freely between states is considered a privilege of national citizenship and hence must be respected by all states, prohibiting any state law that would unduly restrict this freedom.

How does the incorporation doctrine address the application of Bill of Rights protections to the states?

The incorporation doctrine is a legal principle that selectively applies federal Bill of Rights protections to the states through the Due Process Clause of the Fourteenth Amendment. Not all rights are incorporated; the courts apply them on a case-by-case basis.

  • For example: The right to free speech, ensured by the First Amendment, has been incorporated against the states, meaning state laws must not infringe upon an individual’s right to free expression.

In what situations can silence be interpreted as an admission of guilt under legal standards?

Typically, silence cannot be used as an admission of guilt due to the right against self-incrimination. However, in specific contexts where a person would reasonably be expected to speak up, such as during civil depositions or administrative proceedings, their silence might be interpreted against them.

  • For example: If a party in a civil lawsuit fails to deny allegations when given a fair opportunity, their silence could be taken as an admission of those allegations.

References

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