Marshall v. United States
Headline: Court orders new trial after jurors read news reports about defendant’s prior convictions and unlicensed medical practice, finding such publicity likely prevented a fair criminal trial.
Holding: The Court reversed and ordered a new trial because jurors read newspaper reports about the defendant’s prior convictions and unlicensed medical practice, which likely prejudiced his fair-trial rights.
- Requires new trials when jurors read prejudicial news the judge excluded from evidence.
- Reminds judges to protect juries from outside publicity about a defendant’s past misconduct.
Summary
Background
A man was convicted for illegally dispensing dextro amphetamine tablets without a doctor’s prescription, which also caused the pills to be misbranded. He never testified and offered no evidence. The government’s undercover agent said he had been introduced to the man and on two occasions bought the tablets. The defendant asked the judge to rule that he was entrapped (a claim that the government induced him to commit the crime), but the judge left that question for the jury to decide.
Reasoning
During the trial two newspapers published articles reporting the defendant’s prior felony convictions and that he had once practiced medicine without a license. The trial judge had earlier refused to let the government introduce such prior-act evidence because it would be prejudicial. When the judge learned jurors had read the articles, he questioned them individually; seven had seen or scanned the stories and said they would not be influenced. The trial judge denied a mistrial. The Supreme Court held that exposure to news reports of evidence the judge had excluded was likely as prejudicial as introducing that evidence at trial and can be even more harmful, and therefore ordered a new trial under its supervisory power.
Real world impact
The ruling protects defendants from juror exposure to outside news about prior misconduct that a judge has barred from evidence. It makes clear courts must guard jury fairness and may grant new trials when outside publicity undercuts a fair decision on the evidence presented in court.
Dissents or concurrances
One Justice, Mr. Justice Black, dissented from the decision; the opinion notes his disagreement but does not state his reasons in this text.
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