Sparf v. United States

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, 1884, 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 sent, with others, to San Francisco, on the vessel Tropic Bird.^[3]

Decisions of the Court

The court issued its 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]

See also

• List of United States Supreme Court cases, volume 156
• Jury nullification

References

1. 156 U.S. 51 Full text of the opinion courtesy of Findlaw.com.
2. "Sparf and Hansen v. United States 156 U.S. 51 (1895)""Justia U.S. Supreme Court"
3. "U.S. Supreme Court SPARF v. U S""Findlaw"
4. "Sparf and Hansen v. United States""Justia U.S. Supreme Court