Palko v. Connecticut

Facts of the case:

  • Frank Palka, not Palko as erroneously recorded by the clerk of the Supreme Court, was a 23- year old aircraft riveter from Connecticut.
  • One day he broke into a music store, stole a radio, and fled by foot.
    Streets ahead he was cornered by two police officers, he killed both of them.
  • He then escaped, and was arrested one month later.
  • Frank Palka, was charged with 1st degree murder at first but instead he was convicted of the lesser offense of second-degree murder and given a sentence of life imprisonment.
  • A Connecticut Statute allowed the state prosecutor to appeal the judgment of the trial court if there was a serious trial error.
  • A new trial was held, Palka was found guilty of first degree murder and sentenced to death by electrocution.
  • Palka, appealed the second conviction to the Supreme Court arguing that the Fifth Amendment protection against double jeopardy was absorbed into the Fourteenth amendment “due process” clause.

Connecticut’s retrial:

  • The states appeal to re-trial were based on that there had been error of law to the prejudice of the state
    (1) in excluding testimony as to a confession by defendant;
    (2) in excluding testimony upon cross-examination of defendant to impeach his credibility, and
    (3) in the instructions to the jury as to the difference between first and second degree murder.

Decision of the case:

In an 8:1 decision the court validated Frank Palka’s death sentence. This opinion was written in majority by highly respected Justice Benjamin Cardozo.
Cardozo believed and admitted that 1st amendment’s freedoms of speech, assembly, and religion were “fundamental” for society’s liberty and justice.

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by Juan Vizcarrondo