Segurola v. United States

Background

Two men who were riding in a Buick were tried in the federal court in Porto Rico on counts of possessing and transporting intoxicating liquor under the National Prohibition Act. The possession count was set aside on appeal, so the trial and appeal focused on the transportation charge. At arraignment the defendants waived reading of the information and pleaded not guilty. At trial police testimony described a high-speed chase, a crash, and discovery of dozens of bottles of whiskey, brandy, and gin in sacks behind the seat.

Reasoning

The Court reviewed several trial rulings: the trial judge’s refusal to give copies of the information to the defendants without payment, the refusal to allow the officer to say who gave him the tip, and the admission of the seized liquor as evidence despite no search warrant being shown at trial. The Court held the judge was wrong to refuse free copies under the Porto Rico statute, but found that error harmless because the defendants had counsel, waived reading of the charge, and showed no prejudice. The Court also declined to order reversal over the challenged cross-examination and seizure because the defendants never offered evidence to contradict the officers and failed to timely move to suppress or strike the seized liquor.

Real world impact

The decision leaves the convictions and fines intact and makes clear that a defendant’s failure to timely object or offer contradictory evidence can prevent reversal. It also emphasizes that Porto Rico’s statute contemplates free copies of the criminal information, even though harmless-error review may still sustain a conviction.