Wyman v. United States
Headline: Affirms conviction under the National Prohibition Act, rejecting claim that the offense was 'infamous' and required a grand jury, leaving the defendant’s short jail sentence intact.
Holding: The Court affirmed the conviction, holding that the offense under the National Prohibition Act was not an 'infamous' crime requiring indictment by a grand jury, so the defendant's trial and sentence stand.
- Leaves the defendant’s 45-day jail sentence in effect.
- Allows similar Prohibition Act prosecutions on information without grand jury indictment.
- Relies on a companion opinion for the legal rule that prosecutions may proceed.
Summary
Background
The defendant, Wyman, was charged by information with violating a section of the National Prohibition Act. He moved to dismiss, arguing the crime was “infamous” under the Fifth Amendment because federal and New York and New Jersey statutes allowed punishments like imprisonment at hard labor or involuntary labor. Wyman said that, for such an infamous crime, he could only be prosecuted after a grand jury indictment. The motion was denied, he was tried, found guilty, and sentenced to 45 days in Essex County jail in Newark, New Jersey.
Reasoning
The central question was whether the offense was legally an “infamous” crime that required a grand jury indictment. The Court treated this case as legally identical to Brede v. Powers and applied the reasoning explained in that companion opinion. For the reasons given in Brede, the Court rejected Wyman’s argument that the potential punishments made the charge infamous and therefore affirmed the conviction and sentence.
Real world impact
Because the Court affirmed the conviction, Wyman’s 45-day jail sentence stands. The decision means prosecutions under the same provisions of the National Prohibition Act can go forward on information, in similar circumstances, without a grand jury indictment when the Court’s companion opinion controls the legal question. This ruling rests on the Court’s earlier, related analysis rather than new factual findings.
Dissents or concurrances
Justices McReynolds and Brandeis joined only in the result; they “concur in the result,” while the main opinion supplies the controlling explanation.
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