Sparf v. United States

Supreme Court of the United States

Submitted March 5, 1894
Decided January 21, 1895

Full case name

Sparf and Hansen v. United States

Citations

156 U.S. 51 (more)

15 S. Ct. 273; 39 L. Ed. 343; 1895 U.S. LEXIS 2120

Prior history

Error to the Circuit Court of the United States for the Northern District of California

Court membership

Chief Justice Melville Fuller

Associate Justices Stephen J. Field · John M. Harlan Horace Gray · David J. Brewer Henry B. Brown · George Shiras, Jr. Howell E. Jackson · Edward D. White

Case opinions

Majority

Harlan, joined by Fuller, Field, White

Concurrence

Jackson

Dissent

Brewer, joined by Brown

Dissent

Gray, joined by Shiras

Sparf v. United States, 156 U.S. 51 (1895),^[1] also known as Sparf and Hansen v. United States^[2] was a case in which the Supreme Court of the United States held that federal judges were not required to inform jurors of their inherent ability to judge the law in a case. The decision was rendered by a five to four judge margin, with two dissenting opinions. The case distinguished itself from earlier precedent in Georgia v. Brailsford (1794) mandating that jurors be informed by the court of their right to judge the case's facts and law (jury nullification).

Background

On the night of January 13, 1984, on a voyage to Tahiti the second mate of the ship the Hesper, was found to be missing. The man's name was Fitzgerald it was believed that he had been killed, and his body thrown overboard. The Hesper's Captain Sodergren suspected three crew members, men by the name of St. Clair, Hansen, and Sparf, of being participants in the murder. Cpt. Sodergren kept the three suspects in holding until they arrived in Tahiti, where they were taken ashore by the United States consul at that island, and subsequently were sent, with others, to San Francisco, on the vessel Tropic Bird.^[3]

Decisions of the Court

The court issued it's decision on January 21, 1895 by a 5 to 4 vote, with Justice Harlan giving the majority opinion

Confessions in cases of multiple defendants

The courts found that if one of two persons accused of having together committed the crime of murder makes a voluntary confession in the presence of the other without the presence threat or coercion, the confession is admissible in evidence against both. Yet the justices decided that any declarations of one accomplice after the killing made in the absence of the other implicating the guilt of both are only admissible in evidence against the one making the declarations, but not against the other.

Informing Jurors of Jury Nullification

In cases past, it was decided that Judges must inform jurors of their ability to not convict based on the quality of the law the defendant is being charged under. In Sparf v. United States the Justices established that, in the federal courts, jurors only had the right to receive the law from the court, and to apply it as given by the court.^[4]

References

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Sparf v. United States