United States v. Moreland

Background

A man named Moreland was charged in a local Juvenile Court with wilfully failing to support his two minor daughters. The law allowed a conviction to be punished by a fine, or by up to twelve months in the District workhouse at hard labor, or both. Moreland was tried by jury, later sentenced to six months’ hard labor at the workhouse, and the Court of Appeals reversed, finding the sentence violated the Fifth Amendment right against being held to answer for an "infamous" crime except on grand jury presentment or indictment.

Reasoning

The central question was whether a punishment that includes hard labor makes an offense "infamous" so that the accused must be charged by a grand jury before conviction. The majority relied on earlier decisions saying that imprisonment accompanied by hard labor gives a punishment the quality of infamy. Because the statute authorized confinement with hard labor, the Court held that Moreland faced the risk of an infamous punishment and therefore could not be lawfully tried or sentenced without a grand jury indictment. The Court affirmed the lower court’s judgment that the hard‑labor sentence was void under the Fifth Amendment.

Real world impact

The decision prevents courts from imposing hard‑labor sentences when the accused was not first accused by a grand jury where the law authorizes such labor. That affects prosecutions under statutes that authorize workhouse or hard‑labor terms, including some child‑support enforcement cases. The ruling enforces a constitutional protection before a person can be exposed to formally disgraceful punishments.

Dissents or concurrances

Three Justices dissented, arguing the District workhouse (Occoquan) was rehabilitative, not a penitentiary, and that short workhouse sentences under present conditions should not be treated as "infamous."