United States v. Russell

Background

A man named L. C. Russell was indicted under a federal law that makes it a crime to corruptly attempt to influence a juror or otherwise impede the administration of justice. The indictment says Russell went to the home of William D. Russell and asked the juror’s wife to question her husband and report whether he would favor the defendant, offering money in return. The Government did not press the second count, so the case turned on the single charge about trying to influence the juror.

Reasoning

The trial court dismissed the indictment, saying it did not allege enough facts about the juror’s status or the timing and effect of the conversation. The Supreme Court disagreed. It focused on the statute’s use of the word “endeavor,” explaining that the law targets efforts or essays to corrupt a juror, not only successful bribery. The Court held that experimental or preparatory approaches—like asking a juror’s spouse to probe and report—fall within the statute even if the juror was not yet selected or sworn.

Real world impact

The Court reversed the dismissal and sent the case back so the prosecution can proceed. That means officials can bring charges based on efforts to influence summoned jurors before formal selection or swearing, and preliminary acts aimed at testing or securing a juror’s favor may be treated as criminal. This decision resolves only the sufficiency of the indictment and does not decide guilt on the merits.