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Homma v. Patterson
Citation: 327 U.S. 759Docket: 93 Misc. and 818
Court: Supreme Court of the United States; February 11, 1946; Federal Supreme Court; Federal Appellate Court
The Supreme Court denied Masaharu Homma's motions for a writ of habeas corpus, prohibition, and certiorari, citing the precedent set in the Application of Yamashita. Justice Murphy, joined by Justice Rutledge, dissented, emphasizing that the case transcends the guilt of an enemy commander and touches on the nation's honor and future. Murphy criticized the haste of the trial, the use of unconstitutional provisions allowing coerced evidence, and the potential for such actions to set a dangerous precedent for future trials, undermining due process. He argued that justice should reflect constitutional principles rather than revenge, asserting that the integrity of the legal system should not be sacrificed even in the aftermath of war. Justice Rutledge concurred with Murphy's dissent, reiterating the concerns raised in the Yamashita case. The Court's denial of applications affirms the commission's jurisdiction, allowing trials for capital offenses to include forced confessions as admissible evidence. It establishes that prior convictions of group members for mass offenses serve as prima facie evidence of guilt for accused individuals linked to those groups and mandates that findings from mass trials be fully credited in subsequent individual trials. These procedural directives undermine the integrity of the proceedings. Additionally, the defense preparation time was significantly reduced from three weeks to fifteen days, with motions for more time being denied despite claims of inadequate preparation. Other significant concerns about the commission's validity and fairness, not addressed in previous petitions, are also noted. Justice Murphy concurs with this opinion. The directive regulating these trials was issued on December 5, 1945, permitting the admission of confessions without proof of voluntariness and allowing broad hearsay and documentary evidence. The procedural timeline indicates rapid developments, including the appointment of defense counsel and arraignment of the petitioner within a week. The petitioner faced charges similar to those in the Yamashita case, with the commission convening shortly after the charges were filed. The prosecution submitted a bill of particulars addressing two specifications. The petitioner's plea to the jurisdiction and motions to dismiss, as well as motions for bills of particulars concerning specific items, were all denied. Additionally, the defense's request to postpone the trial for ten days was rejected. The defense counsel's affidavit, dated January 2, 1945, detailed that preparation for the defense began on December 16, but the allotted eighteen days was insufficient to investigate the 48 specifications. Issues included two defense staff members who had traveled to Tokyo for witness interviews and had not returned, and two investigators who were hospitalized. The defense had only one additional investigator assigned despite promises for more support. On January 2, the defense received significant evidence from the prosecution that they had not had time to investigate. The affidavit asserted that at least ten more days were necessary for adequate trial preparation. Ultimately, the trial commenced on January 3. On January 16, petitions for writs of habeas corpus and prohibition were filed with the Supreme Court of the Philippines, which were denied on January 23 without argument. Further petitions and motions were filed in this Court on February 7, 1946.