Refusal to Permit to Cross-Examine a Witness Deprived a Fair Trial
In Chambers v. Mississippi, 410 U.S. 284, 93 S. Ct. 1038, 35 L. Ed. 2d 297 (1973), the defendant argued that he was denied due process when on the basis of a Mississippi common-law rule that a party may not impeach his own witness, the trial court refused to allow Chambers to cross-examine witness McDonald about McDonald's prior confession to the murder.
Chambers was also prohibited from calling several witnesses who would have testified that McDonald confessed. Id. at 294.
The United States Supreme Court found that the excluded hearsay statements "bore persuasive assurances of trustworthiness and thus were well within the basic rationale of the exception for declarations against interest." Id. at 302.
As a result, the Supreme Court narrowly held that "under the facts and circumstances of this case," the State's refusal to permit Chambers to cross-examine McDonald coupled with the exclusion of hearsay fitting one of the traditional hearsay exceptions deprived Chambers of a fair trial. Id. at 303.