THE STAR CHAMBER (1983) – A STUDY OF THE DIFFICULTIES OF BEING A JUDGE
Steven Hardin–played by Michael Douglas-is a judge in a Los Angeles criminal court. He listens to oral argument on the admission of evidence in a serial killer murder trial. The evidence is a gun that the defendant placed in his trash can, which was sitting by the curb in front of his house. In his haste, a detective decides to have the trash man empty the can into the trash truck and then search the contents of the can in the holding area of the trash truck. The murder weapon is found and the defendant is charged. At trial, Hardin finds that case law states that the detectives had to get a warrant before they could search the trash; the defendant’s confession is thrown out and his case is dismissed. Hardin has to rule in favor of the defendant because he was bound by the law. He is criticized by the press and blasted by the police department for his decision.
Hardin again has to make a difficult decision in the case of two defendants who were charged with kidnapping and murdering a child. Evidence linking the defendants to the child is located during a questionable search of the defendants’ van during a traffic stop. At trial, the search of the van is in question. The prosecutor does not argue that the police procedure was lawful but rather that the ends justify the means, as the questionable search led to the evidence that could convict the defendants. As Hardin is left with the burden of looking for some sort of case law to support the improper police procedure, the victim’s father visits the judge and shows him pictures of his now-deceased son; he urges Hardin to have the evidence admitted as it is clear the defendants murdered his son. Again, Hardin makes the tough decision to exclude the evidence as it was obtained from improper police procedure. Again, Hardin is roasted by the press and by the victim’s father, who attempted to shoot the defendants.
As Hardin struggles with the aftermath of the decisions he made, he is approached by his friend, mentor, and fellow judge Benjamin Caulfield–played by Hal Holbrook. Hardin wants to know how Caulfield deals with the frustration of making such difficult decisions; Caulfield explains that he is a member of a secret group of judges that rehear the criminal cases that were dismissed under their watch. The group considers the defendant’s guilt or innocence and if the defendant is found guilty, orders the defendant’s death. Caulfield explains that Hardin is invited to be a member of the panel. Hardin joins and begins to feel some relief, but then things take a turn for the worse.
A common theme throughout the story is that the police and the prosecutor appear helpless. They argue that the judge should ignore the law and admit evidence that they know will get overturned on appeal. In the first scenario about the gun in the trash can, the police could have gotten a warrant but did not want to wait around to get one, so they took matters into their own hands. In the second incident, the search of the defendant’s van was based on one officer stating that he smelled marijuana, which the second officer did not support. Both of these incidents were based on poor police work. The prosecutor only argued that the ends justified the means: It’s obvious the defendants are guilty, so just admit the evidence and let the jury will convict them. In reality, while I have seen some questionable police actions, the prosecutor never relies on a “the ends justify the means” argument. Instead, the prosecutor always comes up with a decent argument, which the court usually supports. Furthermore, when officers could have obtained a warrant but simply failed to do so, particularly in a major murder investigation, that failure would likely bring serious scrutiny from supervisors and prosecutors, especially when it results in a murderer going free. Interestingly, the movie's treatment of the trash search reflected a genuine legal issue at the time. Five years after The Star Chamber was released, the United States Supreme Court decided California v. Greenwood (1988), holding that a person has no reasonable expectation of privacy under the Fourth Amendment in garbage left outside the curtilage of the home for collection.
How realistic is it that there is a secret society of judges who review murder cases and pass their own judgments on a trial after an acquittal? Well, there are situations where judges gather annually. I know that in my home state, judges meet yearly for three or four days for training. I am sure that they have discussions about the laws in our state and how to change them or how the laws are changing. It’s also a great opportunity for them to meet up with fellow friends on the bench and catch up with each other. I would not be surprised to learn that some judges gather and discuss old cases that they felt went awry or in which they believed that the defendant got away with murder. However, I do not believe there is a group of judges having former defendants murdered. No rational judge would take that kind of risk because it could potentially unravel all their previous decisions, resulting in convictions being overturned. The Star Chamber is an interesting concept, but I do not believe that it’s realistic.
TF’s Notes: The main reason why I love this movie is that it embraces the difficulty of being a judge. While it is easy to be swayed by horrible facts in a case, by victims and their families pleading for justice, by a defense attorney arguing about a client’s rights, or by the State arguing that the entire case is supported solely by one piece of evidence, the court has to follow the law and the legal precedents before it when making a decision. A judge's job isn't to reach the result that feels right. It is to apply the law to the facts and accept the result—even when everyone in the courtroom wishes the law permitted a different one. Sometimes that decision is easy. Sometimes it results in letting a confessed murderer go free. The Star Chamber shows the audience how heavy that black robe really is.