Frank v. Mangum
United States Supreme Court
237 U.S. 309 (1915)
- Written by Arlyn Katen, JD
Facts
Leo Frank (defendant) was convicted and sentenced to death for the murder of Mary Phagan. During Frank’s four-week trial, the Atlanta courtroom and surrounding area was packed with people hostile to Frank. Tensions were so high that the judge consulted with Atlanta’s police chief and local military personnel in front of the jury and delayed proceedings. The following court day, the crowd applauded when the solicitor general entered the courtroom. Before charging the jury, the judge privately consulted with defense counsel, who agreed that defense counsel and Frank would not be present during the jury’s verdict because of the danger of violence. When the jury delivered its guilty verdict, the crowd cheered so loudly that the court had to pause jury polling. Frank appealed his conviction. The Georgia Supreme Court determined that Frank’s facts and claims were either unfounded or harmless error. Frank filed a habeas petition in federal district court, arguing that his constitutional right to due process was violated because his trial proceedings were a mob-dominated empty formality and that he was improperly prevented from being present during the verdict. The district court denied Frank’s petition, and the United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Pitney, J.)
Dissent (Holmes, J.)
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