Rubin “Hurricane” Carter: Case, Retrials, and Sarokin Ruling

The Rubin “Hurricane” Carter case is the story of a professional middleweight boxer twice convicted of a 1966 triple murder at a Paterson, New Jersey bar, who served nearly 20 years in prison before a federal judge threw out both convictions in 1985, ruling that prosecutors had won them through concealed evidence and appeals to racial prejudice. Carter and his co-defendant John Artis were never formally declared innocent by any court, and the case remains contested among people who have studied it, but the state chose not to try them a third time and the indictments were dismissed in 1988.

The Shootings at the Lafayette Bar and Grill

Just after 2:30 a.m. on June 17, 1966, two men walked into the Lafayette Bar and Grill at East 18th and Lafayette Streets in Paterson and opened fire with a .32 caliber pistol and a 12-gauge shotgun. Bartender James Oliver and patron Fred Nauyoks died at the scene. Hazel Tanis died of her injuries about a month later. A fourth person, Willie Marins, was seriously wounded but survived.¹

Police stopped Rubin Carter and John Artis that same night in Carter’s white 1966 Dodge Polara, which matched a general description of the suspects’ car. Marins was asked at the hospital to identify the two men and shook his head no. Both were released.² Four months later, Carter and Artis were arrested and charged with three counts of first-degree murder.

Who Rubin Carter Was Before the Case

Carter was born on May 6, 1937, in Clifton, New Jersey, and raised in Paterson. He had a long juvenile and criminal record before boxing: a stabbing at age 11 sent him to a reformatory, he escaped in 1954, joined the Army under a false hometown to hide his record, and picked up boxing on the Army team in West Germany. He was discharged in 1956 after four court-martials, and later served prison time in New Jersey for muggings before his release in September 1961.¹

He turned professional almost immediately, debuting on September 22, 1961, and finished with a record of 27 wins, 12 losses, and 1 draw, with 19 knockouts.³⁴ His signature win was a first-round knockout of welterweight champion Emile Griffith on December 20, 1963. He lost a 15-round unanimous decision to Joey Giardello for the WBC world middleweight title on December 14, 1964, and his career declined afterward. His last fight, a loss to Juan “Rocky” Rivero, took place on August 6, 1966, about two months after the Lafayette Bar shootings.

The 1967 Trial and Conviction

Carter and Artis went to trial in Paterson in spring 1967. The state’s case rested heavily on two eyewitnesses, Alfred Bello and Arthur Dexter Bradley, both career criminals who had been burglarizing a nearby building at the time of the murders. Both said they saw Carter and Artis leaving the bar.⁵ Police also pointed to a .32 caliber bullet and a 12-gauge shotgun shell found in the trunk of Carter’s car. The items were not logged until five days after the car was impounded, and neither matched the actual weapons used in the killings.¹

The defense case pointed to what was missing. No murder weapons were recovered. No blood was found on the defendants or their belongings. Surviving victim Willie Marins had failed to identify either man, and his description of the shooters did not match Carter or Artis. The jury was all white, with a single Black alternate who did not participate in deliberations.⁶

On May 27, 1967, both men were convicted. Judge Samuel Larner sentenced Carter to one concurrent and two consecutive life terms and Artis to three concurrent life terms.¹

Recantations, the 1976 Retrial, and a Second Conviction

In 1974, Carter published a memoir from Rahway State Prison, The Sixteenth Round: From Number 1 Contender to #45472.⁷ The book drew Bob Dylan to the case, and Dylan’s 1975 song “Hurricane” made it a national cause.⁸

That same year, Bello and Bradley recanted their trial testimony, saying police and prosecutors had pressured them to identify Carter and Artis.⁹ A tape-recorded interview then surfaced showing that state officials had promised Bello a lighter sentence for his identification, a deal the prosecution had never disclosed to the defense.² In March 1976, the New Jersey Supreme Court threw out both convictions, finding that prosecutors had suppressed the taped interview and allowed false testimony about the treatment their witnesses were receiving.⁶

The retrial began in December 1976, and this time the prosecution shifted its theory. It argued that Carter and Artis had committed the shootings as “racial revenge” for the murder of a Black bar owner, Leroy Holloway, who had been killed by a white man earlier the same night.¹⁰ Two Black jurors sat on the panel this time.⁶

Bello testified again. He now told the jury his earlier recantation had itself been prompted by a $27,000 offer from the defense. Four alibi witnesses from the first trial also reversed themselves, testifying that they had lied for Carter in 1967.¹¹ Carter and Artis were convicted again, and the earlier sentences were reinstated.¹

Judge Sarokin’s 1985 Ruling

On November 7, 1985, U.S. District Judge H. Lee Sarokin granted a writ of habeas corpus in Carter v. Rafferty, vacating both convictions. Sarokin wrote that the convictions were “predicated upon an appeal to racism rather than reason, and concealment rather than disclosure.”¹² He found the racial revenge theory baseless and unconstitutional, ruled that prosecutors had withheld evidence including a recorded polygraph result that would have undermined Bello’s credibility, and concluded the jury had been “permitted to draw inferences of guilt based solely upon the race of the defendants.”¹³

Carter walked out of Rahway State Prison on bail on November 8, 1985, at age 48.¹ The Passaic County prosecutor appealed, and on August 21, 1987, the Third U.S. Circuit Court of Appeals upheld Sarokin’s ruling. The U.S. Supreme Court declined to hear the case on January 11, 1988.¹⁴ With its main witness discredited and the case more than 20 years old, the state chose not to seek a third trial. The indictments were formally dismissed on February 26, 1988.³

Why the Case Is Still Debated

Carter’s release was a constitutional ruling, not a finding of innocence. Two juries convicted him, and the federal courts held only that his rights had been violated by concealed evidence and a racially inflammatory trial strategy. No court has formally declared him innocent.

Critics point to the second trial: four alibi witnesses from 1967 testified in 1976 that they had lied for Carter, and Bello told the second jury that his own recantation had been bought. Reporter Cal Deal, who maintains an archive of case documents, has called the exoneration narrative a “Carter myth.”¹¹ Co-defendant John Artis never publicly corroborated Carter’s account of their movements that night.

Supporters point to what the state never produced. No murder weapon was recovered. No blood was found on either defendant or their clothing. The ammunition in Carter’s car did not match the guns used in the killings. The surviving victim could not identify either man. The state’s key witnesses were criminals who admitted to hoping for favorable treatment in return for their testimony.⁶

Life After Prison

After the charges were dismissed in 1988, Carter moved to Toronto and turned to advocacy. From 1993 to 2004 he served as executive director of the Association in Defence of the Wrongly Convicted, and in 2004 he founded his own nonprofit, Innocence International.⁸⁹ He lectured on the justice system, campaigned for individual prisoners including David McCallum, and received honorary doctorates from Griffith University and York University in 2005 and an honorary championship belt from the World Boxing Council in 1993. He published a second memoir, Eye of the Hurricane: My Path from Darkness to Freedom, in 2011. The 1999 film The Hurricane, starring Denzel Washington, was based on his story.

Artis was paroled in 1981 after 15 years in prison, from age 20 to 35, and later settled in Virginia, where he worked at the Norfolk Juvenile Detention Center counseling young people.¹⁵ He died on November 7, 2021, at 75 in Hampton, Virginia.¹⁶

Rubin Carter died on April 20, 2014, at 76 in Toronto, from prostate cancer. In a February 2014 opinion piece on David McCallum’s case, one of his last published writings, he wrote: “To live in a world where truth matters and justice, however late, really happens, that world would be heaven enough for us all.”⁹

1
National Park Service. Hurricane Carter
2
BLHNY. Rubin Carter
3
ESPN. Hurricane Carter Biography
4
BoxRec. Rubin Carter
5
University of Virginia Law Library. Boxer Rubin Hurricane Carter Trial for Murder
6
National Registry of Exonerations. Rubin Carter
7
The New York Times. The Sixteenth Round
8
Tufts University Archival Research Center. Rubin Hurricane Carter Papers
9
Equal Justice Initiative. EJI Celebrates Life of Rubin Carter
10
Tufts University. Rubin Carter Papers Open for Research
11
NJ.com. Spare Us the Lies About the Late Hurricane Carter
12
New York Law School Digital Commons. Carter v. Rafferty, 631 F. Supp. 533
13
Los Angeles Times. Court Overturns Hurricane Carter Murder Conviction
14
Maykuth Archives. Carter Case Supreme Court
15
Centurion Ministries. John Artis, the Unsung Hero
16
The New York Times. John Artis Dead