Sarah Blackmon
ROCHIN v. CALIFORNIA
342 U.S 165, 72 S.Ct. 205, 96 L.Ed. 183 (1952)
Facts:
Having “some information” that the accused was selling narcotics, Los Angeles police
officers entered the home of the accused after finding the door unlocked and entered the
bedroom where the accused was sitting. When questioned as to what the two pill capsules on his
nightstand contained the accused swallowed them and refused to spit them out even after the
police officers forcibly attempted to remove them from his mouth. Rochin was then handcuffed
and then taken to a hospital where a doctor was instructed by one of the officers to pump
Rochin’s stomach without any consent from the accused. The contents of his stomach were
evaluated and the capsules found to contain morphine. Rochin was convicted to 60 days
imprisonment on the charges of possessing the illegal substance, despite protests from the
petitioner not to admit the forcibly obtained evidence that convicted him.
Procedural History:
Rochin was tried before a California Superior Court and convicted. The District Court of
Appeal again affirmed his conviction even though they found the officers guilty of “shocking
series of violations of constitutional rights”. The Supreme Court of California denied Rochin’s
petition for appeal, however two dissenting justices appealed to the Supreme Court and certiorari
was granted on the question of limitations of the Fourteenth Amendment and Due Process of
criminal proceedings by the states.
Issue:
Does Due Process as mentioned in the 14th amendment protect the accused from
convictions based on evidence or confessions obtained by coercion?
Infringement of Laws in Question:
Was the 14th amendment violated by the disregard to Due Process by forcibly obtaining
the evidence used to convict the accused? Should protection under the 5th and 4th amendments be
extended to state criminal trials when a confession or self incrimination is achieved by coercion?
Decision/Rationale:
The decision of the Supreme Court was that the accused was protected from conviction
and the judgment to be reversed based on the evidence used to convict the petitioner was
obtained using methods that offend the Due Process Clause.
Two Justices concurred with this decision, however they dissented on the rationale that
the basis of the opinion was too subjective as explained by the “decencies of civilized conduct”
determining Due Process. Instead of rationalizing the ambiguity of the Due Process Clause
Justices Black and Douglas wrote in their opinion that that the 5th amendment protecting the
accused from self incrimination should instead be considered Due Process. Evidence taken from
the accused without his consent is inadmissible because of the 5th amendment.