Johnson v. United States

Background

Johnson was indicted, tried, and convicted in the District of Columbia for the murder of one Ofenstein and was sentenced to death. He asked the trial court to arrest the judgment and grant a new trial, raising three issues: whether he had been properly arraigned, whether a jury could add the words “without capital punishment” to a guilty verdict, and whether the jury had been legally selected.

Reasoning

On the arraignment question the Court examined the record, which showed the defendant and his lawyer present and the plea of not guilty entered, and concluded the record fairly shows the arraignment and plea and that required copies of the indictment were presumed delivered. On the jury-verdict question the Court compared earlier federal laws, the 1897 act allowing qualified verdicts, the District Code (which divided murder into degrees and removed the qualified verdict), and the 1909 Criminal Code. Reading those provisions together, the Court concluded the Criminal Code’s chapter defining murder and its trial provisions did not apply to the District of Columbia and that the District Code governs sentencing and verdict form in the District. On jury selection the Court held the complaint was made too late—challenges to juror competency must be raised at trial before jurors are sworn.

Real world impact

The practical outcome is that Johnson’s conviction and sentence were affirmed. For future cases in the District of Columbia, the local criminal code controls how murder is tried and sentenced, defendants should insist on jury-selection challenges at trial, and courts may accept a record’s plain statements as showing an arraignment.