Chandler v. Florida
Annotate this Case
449 U.S. 560 (1981)
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U.S. Supreme Court
Chandler v. Florida, 449 U.S. 560 (1981)
Chandler v. Florida
Argued November 12, 1980
Decided January 26, 1981
449 U.S. 560
The Florida Supreme Court, following a pilot program for televising judicial proceedings in the State, promulgated a revised Canon 3A (7) of the Florida Code of Judicial Conduct. The Canon permits electronic media and still photography coverage of judicial proceedings, subject to the control of the presiding judge and to implementing guidelines placing on trial judges obligations to protect the fundamental right of the accused in a criminal case to a fair trial. Appellants, who were charged with a crime that attracted media attention, were convicted after a jury trial in a Florida trial court over objections that the televising and broadcast of parts of their trial denied them a fair and impartial trial. The Florida District Court of Appeal affirmed, finding no evidence that the presence of a television camera hampered appellants in presenting their case, deprived them of an impartial jury, or impaired the fairness of the trial. The Florida Supreme Court denied review. The Florida courts did not construe Estes v. Texas, 381 U. S. 532, as laying down a per se constitutional rule barring broadcast coverage under all circumstances.
Held: The Constitution does not prohibit a state from experimenting with a program such as is authorized by Florida's Canon 3A(7). Pp. 449 U. S. 569-583.
(a) This Court has no supervisory jurisdiction over state courts, and, in reviewing a state court judgment, is confined to evaluating it in relation to the Federal Constitution. P. 449 U. S. 570.
(b) Estes v. Texas, supra, did not announce a constitutional rule that all photographic, radio, and television coverage of criminal trials is inherently a denial of due process. It does not stand as an absolute ban on state experimentation with an evolving technology, which, in terms of modes of mas communication, was in its relative infancy in 1964 when Estes was decided, and is, even now, in a state of continuing change. Pp. 449 U. S. 570-574.
(c) An absolute constitutional ban on broadcast coverage of trials cannot be justified simply because there is a danger that, in some cases, conduct of the broadcasting process or prejudicial broadcast accounts of pretrial and trial events may impair the ability of jurors to decide the issue of guilt or innocence uninfluenced by extraneous matter. The appropriate safeguard against juror prejudice is the defendant's right
to demonstrate that the media's coverage of his case -- be it printed or broadcast compromised the ability of the particular jury that heard the case to adjudicate fairly. Pp. 449 U. S. 574-575.
(d) Whatever may be the "mischievous potentialities [of broadcast coverage] for intruding upon the detached atmosphere which should always surround the judicial process," Estes v. Texas, supra at 381 U. S. 587, at present no one has presented empirical data sufficient to establish that the mere presence of the broadcast media in the courtroom inherently has an adverse effect on that process under all circumstances. Here, appellants have offered nothing to demonstrate that their trial was subtly tainted by broadcast coverage -- let alone that all broadcast trials would be so tainted. Pp. 449 U. S. 575-580.
(e) Nor have appellants shown either that the media's coverage of their trial -- printed or broadcast -- compromised the jury's ability to judge them fairly, or that the broadcast coverage of their particular trial had an adverse impact on the trial participants sufficient to constitute a denial of due process. Pp. 449 U. S. 580-582.
(f) Absent a showing of prejudice of constitutional dimensions to these appellants, there is no reason for this Court either to endorse or to invalidate Florida's experiment. P. 449 U. S. 582.
376 So.2d 1157, affirmed.
BURGER, C.J., delivered the opinion of the Court, in which BRENNAN, MARSHALL, BLACKMUN, POWELL, and REHNQUIST, JJ., joined. STEWART, J., filed an opinion concurring in the result, post, p. 449 U. S. 583. WHITE, J., filed an opinion concurring in the judgment, post, p. 449 U. S. 586. STEVENS, J., took no part in the decision of the case.