Gompers v. United States
Headline: Court applies three-year criminal statute of limitations to contempt prosecutions, reversing many punishments for older actions and limiting courts’ ability to punish long-past violations of orders.
Holding: The Court held that the three-year criminal statute of limitations covers contempts, so many convictions for acts older than three years must be reversed.
- Bars contempt punishment when prosecution begins more than three years after the act.
- Reverses convictions based on violations older than three years.
- Forces courts to start contempt cases promptly to avoid being time-barred.
Summary
Background
A labor leader named Gompers and two associates were charged with violating a court order that barred a boycott and related publications against the Bucks Stove and Range Company. The preliminary injunction was entered in December 1907 (operative December 23) and made final in March 1908. After this Court decided the earlier civil case in May 1911, the local court appointed a committee, filed charges in June 1911, and at trial the defendants were found guilty of many acts mainly from 1908–1909 and sentenced; the Court of Appeals reduced some punishments and the defendants sought review here.
Reasoning
The main question was whether the three-year criminal statute of limitations (Rev. Stat. § 1044) applies to contempts like these. The Court held that contempts are offenses within the statute’s general words barring prosecution, trial, or punishment after three years, and that by analogy the power to punish contempt must have a time limit consistent with legal policy. The Court assumed the evidence supported guilt for some acts but concluded many charged acts were too old to be punished under the three-year rule, so the convictions based on those acts could not stand.
Real world impact
The ruling prevents punishment for contempt when prosecution begins more than three years after the alleged act. Individuals and organizations accused of violating court orders will face a clear time limit for government action. Courts must bring contempt prosecutions promptly or risk reversal of convictions and penalties.
Dissents or concurrances
Two Justices (Van Devanter and Pitney) dissented from the Court’s decision.
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