..,,^;■ ^!\.
OJorn^U ICam ^rl^ool Htbratg
Cornell University Library
KF 9218.M63C3
V.I
Cases on criminal law :a selection of re
3 1924 019 413 370
Cornell University
Library
The original of tiiis book is in
tine Cornell University Library.
There are no known copyright restrictions in
the United States on the use of the text.
http://www.archive.org/details/cu31924019413370
CASES ON CRIMINAL LAW.
A SELECTION OF REPORTED CASES ON THE
CRIMINAL LAW.
WILLIAM E. MIKELL,
Assistant Professor of Law in tlie University of Pennsylvania.
PHILADELPHIA:
INTERNATIONAL PRINTING CO.
1902
Copyright, 1903
By William E. Mikell.
PREFACE.
This collection of cases is intended for use as a text book in
teaching the principles of the criminal law. In the selection of the
cases the object has been to present the law as it is ; to trace its
growth to its present state, and to indicate its future development.
Owing to the lack of unity of the subject — so large a part of
it having to do with specific crimes bearing little or no relation to
each other — it does not lend itself to acute analysis and, in the
arrangement of the topics treated in this book, an attempt at such
analysis has been subordinated to the practical consideration of
presenting to the student the simpler before the more difficult
topics.
Portions of some of the cases reprinted have been omitted,
but such portions are either irrelevant or cumulative, and in no
case restrictive of the principle for which the case is cited. Where
a case has not been reprinted in full the fact has been noted.
The second part of this book, containing cases on specific
crimes, is in course of preparation, and will soon be ready for
publication.
WILLIAM E. MIKELL.
Sewanee, Tennessee.
September, 1 902.
T.A.BILE OF OOISTTEnSTTS-
CHAPTER I.
Sources of the Criminal Law.
Page
Section I. Criminal Law of the Federal Government i
Section II. Criminal Law of the States
CHAPTER II.
The Elements of Crime.
Section I. Union of Intent and Act 20
Section II. Offenses against Public Justice and Authority .... 21
Section III. Offenses against the Law of Nations 33
Section IV. Offenses against Religion 36
Section V. Offenses against Public Peace . . ■ • ■ 41
Section VI. Offenses against Public Health 52
Section VII. Offenses against Trade .... 56
Section VIII. Offenses against Public Decency 59
Section IX. Effect of Consent, Condonation, etc.
a. Consent of the Person Injured . . . . 68
6. Consent of the State 86
c. Negligence of the Person Injured ... -9°
d. Guilt of the Person Injured . . 96
e. Condonation of the Person Injured 100
/. Condonation of the State 105
^. Custom • 106
Table of Contents. — Continued.
Page
Section X. Effect of Coercion
a. Coverture I09
b. Command • ■ II4
6. Threats ii7
d. Necessity 128
CHAPTER III.
The Criminal Intent.
Section I. General Principles 134
Section II. Distinction between Intent and Motive 139
Section III. Constructive Intent . 148
Section IV. Specific Intent 167
Section V. Intent in Statutory Crimes 173
Section VI. Concurrence of Several Intents 211
CHAPTER IV.
Negligence as Supplying Intent 215
CHAPTER V.
Intent as Affected by Conditions.
Section I. Ignorance or Mistake of Law 237
Section II. Ignorance or Mistake of Fact 244
Section III. Infancy
a. Responsibility of Infants 252
b. Proof of Age 255
Section IV. Insanity
a. Test of Insanity 256
b. Proof of Insanity 297
Section V. Intoxication 311
Section VI. Incorporation 328
Table of Contents. — Continued.
CHAPTER VI.
The Criminal Act.
Section I. Concurrence of Act and Intent . . .
Section II. Sufficiency of the Act
a. Solicitation . .
b. Attempt . .
c. Conspiracy
Section III. Authorized Acts
a. Acts in Furtherance of Public Justice
b. Acts in Furtherance of Domestic Authority
c. Acts in Prevention of Crime
d. Acts in Self Defense . .
e. Acts in Defense of Others
f. Acts in Defense of Property . .
g. Acts in Defense of Dwelling ...
Page
333
336
342
358
392
399
406
411
433
446
450
CHAPTER VII.
Combinations of Persons in Crime.
Section I. Principal in the First Degree . .
Section II. Principal in the Second Degree . .
Section III. Accessory Before the Fact ....
Section IV. Accessory After the Fact
Section V. Principal and Agent . . .
457
467
487
495
502
[end of part lJ
T-A.BX.E OF C.A.SES-
A.
Page
Abley, St. z/ 83
Adams, Com. v. . . . 160
Allen, St. z/. . . 483
Anderson ii. Com 64
z/. St 449
Anon 21
328
411
Arnold, St. z' 255
Arp z/. St 121
Ashton, U. S. z/. .... 128
Axtell's Case 114
B.
Bacon's Case 336
Bain i/. St 118
Hansen v. Ossley . ... 467
Beard v. V. S 416
Beck, St. 7/ 68
Bell 7/. St. 59
Bibithe's Case 492
Boyett, St. z/. . 238
Bradley v. Wife 399
Buchanan, St. f 358
Butterfield, Reg. v. . . . 499
Button, P. ?/ 421
Bykerdike, Rex v 362
C.
Campbell v. Com 492
Carroll z/. St 45'
Cassidy, Com. v. .... 54
Champer z/. St 69
Clark z/. St 355
Coleman, St. z/ 139
Coney, Reg. v 70
Connolly's Case . . . . no
Cooper, Rex z' 488
Cote V. Murphy 367
Covington, St. v. . . 77
Cox, St. z/. 483 n
Cramer, Com. v 47
Cunningham z/. St 306
Cutter z/. St 241
Page
Dade, Rex v 461
Dalrymple, P. z/ 102
Darby, Rex z/ 21
Davis, St. z/ 496
De Longchamps, Resp. v. . . 33
De Ranc6, St. z/ 302
Desvignes, Reg. v 96 n
Dill z/. St. . . .... 392
Dixon, Rex v 137
Doddridge, Reg. v 170
Doud, St. z/. . . 32
Dudley, Reg. v. . . . . 131 n
Duffin, Rex. v 167
Ellis, St. z'
Evanston, City of, v. Myers
Eversvale v. Com. . . .
F.
Fain v. Com.
Flack, P. w. . .
Flanigan z;. P.
Flatman, Reg. v.
Floyd V. St. . . .
Ford's Case. .
Foster v. Com. .
Franklin, Reg. v.
■ 23
. 88
453 n
297
138
316
459
412
450
355 n
, 158
G.
Gardiner z/. P 358 n
Gillow, Rex V. 213
Godfrey z/. St 252
Goff, St. z/ -132
Goodall z/. St 413
Grey' s Case 400
Griffith' s Case 467
Grisham z/. St 19 n
Guardians of Poor v. Greene . 5
Gufifee z/. St 437
Gut, St. z/ 87n
Table of Cases. — Continued.
H.
Haab, St. v. .
Haines, Com. v.
Halstead v. St.
Harrison, St. v.
Hartigan, St. v.
Higgins, Rex v.
Hinchliffe' s Case .
Homer, U. S. v.
Holt, Rex V. .
Houston, St. V.
Howell's Case .
Hughes, Rex v.
Hull's Case . .
Hunt, Rex v.
Hutchinson, Com. v.
I.
Isham V. St.
Page
320
41
192
263
72
337
446
i32n
169
iiin
406
110
215
152
338
148
M.— (Continued.)
Page
Marshall's Case 311
Martin, V. v. . . . . 98
Mather, V. v • ■ 385
Matthews, Reg. v 333
Mercersmith v. St. . . 477
Merritt v. State 259
Mesca, Respub. v. . . . 10
Middleton w. St. . . . . 57
Miers w. St . 429
Milton ^/. St 334
Moore, U. S. w 234
Morgan, St. v. . . . 447
Morrison, Penna. v. . . . . 22
Mosler, Com. v. . . . . . 260
N.
Nash, St. V. . .
Nickerson, Com. v.
248
75
James v. Com.
Jarvis, Rex v. .
Jefifries, Reg. v.
Jones, St. V. .
K.
Keenan v. Com. . .
Kelly V. Com. .
Kelly, Rex v. . . .
Kelso Co., U. S. V.
Kirby, V. v.
Knight's Case . . .
L.
Latimer, Reg. v. .
Lawrence v. St. .
Leonine's Case
Lesley, Reg. v. . .
Longbottom, Reg. i/.
7
49911
464
275
312
342
488
328
142
217
163
106
393
86
94
M.
M' Carney w. P 468
McHale, Com. v 27
Macleod, Reg. v 220
McNaghten's Case 256
M'Phane, Reg. v 465
Ma Foo, St. z/ 113
Manley, Reg. v. . . . 457
Marley w. St 352
Marriott, Reg. v 229
O'Brien, St. v. .
Oliver, St. v.
Ortwein v. Com.
218
399
297
P.
Packard, Reg. v. . . 154
Palmer, St. -z/ 297
Parker, St. i/ 15
Patten w. P 433
Peaslee, Com. v. . . 348
Pembliton, Reg. v 171
Pinkard z/. St 335
Pocock, Reg. V. . . ... 233
Powell, Respub. v 56
Poynier, St. 7'. . . .... 470
Prince, Reg. v 173
Presby, Com. v. . 244
Pulle, St. z/. . . ... 16
R.
Regan, Rex z/ 141
Rice, U. S. z/ 394
Richards v. Richards . . 4oon
Riggs z/. St 114
Rigmaidon's Case ... 217
Robert's Case 100
495
Roberts, Respub. v 13
Rohrheimer v. Winters .... 103
Rosinski, Rex v 74
Ruggles, P. 7/ 36
Table of Cases. — Continued.
S.
Page
Saunders' Case 490
Savage v. State 475
Seed, Com. v. . . 402
Seiler v. P. . ... 112
Senior, Reg. v 143
Shannon zi. Com. . . . 383
Shepherd, Reg. v 223
Sheriff, Com. v 363
Simpson v. St 345
Speiden z/. SL . . . . 80
Stanton, St i>. . . . . i6i
Stern 7/. St 202
Stevens, Com. 1/. . . 502
Stewart, St. ^/. . . . . 377
St. John, Com. v. 105
Storey v. St. . . . 406
Summers, Rex v. . -41
Sutton, Rex v 335
X,— COontinued.)
Taylor, Com. v.
Rex V. . .
Thomas, Rex v. .
Thurston, Rex v.
44
52
311
237
Tolson, Rex v.
Tracy, Reg. v.
Vantandillo, Rex v.
Vigol, U. S. V.
Page
178
489
53
117
w.
Waters, Rex v. . . -9°
Webster, Rex v. . . . 96
Weiss, Com. v. . . . 205
White V. F .480
Whitten v. St 326
Williams 2/. St 100
■_ — St. V. . . . . 63
Rex V. . . ... 23
Rex V 211
Williamson, Reg. v i
Worrall, U. S. ^ 91
Wray, St. ■z/ 209
Yoes V. St.
" No department of law can claim greater moral importance
than that which, with the detail and precision necessary for legal
purposes, stigmatizes certain kinds of conduct as crimes, the com-
mission of which involves, if detected, indelible infamy and the
loss, as the case may be, of life, property or personal liberty."
1 Stephens' History of Criminal Law, ix.
Chapter I.
Sources of the Criminal Law.
SECTION I.
CRIMINAL LAW OF THE FEDERAL
GOVERNMENT.
UNITED STATES v. WORRALL.
Circuit Court of United States, Pennsylvania District, 1798.
2 Dallas, 384.
The defendant was charged with an attempt to bribe Tench
Coxe, the Commissioner of the Revenue, the indictment containing
two counts. Verdict — Guilty on both counts of the indictment.^
Dallas (who had declined speaking on the facts before the
jury) now moved in arrest of judgment.
Rawle (District Attorney) contra.
Chase, Justice. Do you mean, Mr. Attorney, to support this
indictment solely at common law? If you do, I have no difficulty
upon the subject. The indictment cannot be maintained in this
Court.
Rawle, answering in the affirmative, Chase, Justice, stopped
Mr. Levy, who was about to reply, in support of the motion in
arrest of judgment ; and delivered an opinion to the following
effect :
Chase, Justice. This is an indictment for an offence highly
injurious to morals, and deserving the severest punishment ; but»
as it is an indictment at common law, I dismiss, at once, every-
thing that has been said about the Constitution and Laws of the
United States.
' Part of this case is omitted.
2 Cases on Criminal Law.
In this country, every man sustains a two-fold political capacity;
one in relation to the State, and another in relation to the United
States. In relation to the State, he is subject to various municipal
regulations, founded upon the State Constitution and policy, which
do not affect him in his relation to the United States ; for the Con-
stitution of the Union is the source of all the jurisdiction of the
national government; so that the departments of the government can
never assume any power that is not expressly granted by that instru-
ment, nor exercise a power in any other manner than is there pre-
scribed. Besides the particular cases, which the eighth section of
the first article designates, there is a power granted to Congress to
create, define and punish crimes and offences, whenever they shall
deem it necessary and proper by law to do so, for effectuating the
objects of the government; and although bribery is not among the
crimes and ofTences specifically mentioned, it is certainly included
in this general provision. The question, however, does not arise
about the power ; but about the exercise of the power : — Whether
the Courts of the United States can punish a man for any act,
before it is declared by a law of the United States to be criminal ?
Now, it appears to my mind, to be as essential, that Congress
should define the offences to be tried, and apportion the punish-
ments to be inflicted, as that they should erect Courts to try the
criminal, or to pronounce a sentence on conviction.
It is attempted, however, to supply the silence of the Consti-
tution and Statutes of the Union by resorting to the common law
for a definition and punishment of the offence which has been
committed ; but, in my opinion, the United States, as a Federal
government, have no common law ; and, consequently, no indict-
ment can be maintained in their Courts for offences merely at the
common law. If, indeed, the United States can be supposed, for a
moment, to have a common law, it must, I presume, be that of
England ; and, yet, it is impossible to trace when or how the
system was adopted or introduced. With respect to the individual
States, the difficulty does not occur. When the American colonies
were first settled by our ancestors, it was held, as well by the set-
tlers as by the judges and lawyers of England, that they brought
hither, as a birthright and inheritance, so much of the common
law as was applicable to their local situation and change of cir-
cumstances. But each colony judged for itself what parts of the
Cases on Criminal Law. 3
common law were applicable to its new condition ; and in various
nrtodes, by legislative acts, by judicial decisions, or by constant
usage, adopted some parts and rejected others. Hence, he who
shall travel through the different States will soon discover that the
whole of the common law of England has been nowhere intro-
duced ; that some States have rejected what others have adopted ;
and that there is, in short, a great and essential diversity in the
subjects to which the common law is applied, as well as in the
extent of its application. The common law, therefore, of one
State is not the common law of another ; but the common law of
England is the law of each State, so far as each State has adopted
it ; and it results from that position, connected with the judicial
act, that the common law will always apply to suits between citizen
and citizen, whether they are instituted in a Federal or State Court.
But the question recurs, when and how have the Courts of
the United States acquired a common law jurisdiction in criminal
cases? The United States must possess the common law them-
selves before they can communicate it to their judicial agents.
Now, the United States did not bring it with them from England ;
the Constitution does not create it ; and no act of Congress has
assumed it. Besides, what is the common law to which we are
referred ? Is it the common law entire, as it exists in England ; or
modified as it exists in some of the States ; and of the various
modifications which are we to select, the system of Georgia or
New Hampshire, of Pennsylvania or Connecticut ?
Upon the whole, it may be a defect in our political institu-
tions, it may be an inconvenience in the administration of justice,
that the common law authority, relating to crimes and punish-
ments, has not been conferred upon the government of the United
States, which is a government in other respects also of a limited
jurisdiction; but judges cannot remedy. political imperfections, nor
supply any legislative omission. I will not say whether the offence
is at this time cognizable in a State Court. But, certainly, Con-
gress might have provided by law for the present case, as they
have provided for other cases of a similar nature ; and yet if Con-
gress had ever declared and defined the offence, without prescribing
a punishment, I should still have thought it improper to exercise a
discretion upon that part of the subject.
Peters, Justice. Whenever a government has been estab-
4 Cases on Criminal Law.
lished, I have always supposed that a power to preserve itself was
a necessary and an inseparable concomitant. But the existence of
the Federal government would be precarious, it could no longer be
called an independent government, if, for the punishment of offences
of this nature, tending to obstruct and pervert the administration
of its affairs, an appeal must be made to the State tribunals, or the
offenders must escape with absolute impunity.
The power to punish misdemeanors is originally and strictly
a common law power, of which, I think, the United States are
constitutionally possessed. It might have been exercised by Con-
gress in the form of a legislative act ; but it may, also, in my
opinion, be enforced in a course of judicial proceeding. When-
ever an offence aims at the subversion of any Federal institution,
or at the corruption of its public officers, it is an offence against
the well-being of the United States; from its very nature, it is
cognizable under their authority ; and, consequently, it is within
the jurisdiction of this Court, by virtue of the eleventh section of
the Judicial Act.
The Court being divided in opinion, it became a doubt
whether sentence could be pronounced upon the defendant ; and
a wish was expressed by the Judges and the Attorney of the Dis-
trict that the case might be put into such a form as would admit
of obtaining the ultimate decision of the Supreme Court upon the
important principle of the discussion. But the counsel for the
prisoner did not think themselves authorized to enter into a com-
promise of that nature. The Court, after a short consultation, and
declaring that the sentence .was mitigated in consideration of the
defendant's circumstances, proceeded to adjudge :
That the defendant be imprisoned for three months ; that he
pay a. fine of 200 dollars; and that he stand committed till this
sentence be complied with, and the costs of prosecution paid.^
1 In 1812, the Supreme Court of the United States, in U. S. v. Hudson,
7 Cranch, 32, decided, without argument, that while certain implied powers to
fine for contempt, imprison for contumacy, to enforce the observance of
order, etc. , necessarily resulted to the Federal Courts from the nature of their
institution, the exercise of criminal jurisdiction in common law cases was not
within their implied powers. In 1816, the same point arose in U. S. v.
Coolidge, I Wheaton, 415. Story, J., said he did not consider the question
settled by U. S. v. Hudson. Washington and Livingston, JJ., desired the
point argued, and Johnson, J., considered the question no longer an open
one; but the Attorney General refusing to argue the point, and no counsel
Cases on Criminal Law.
SECTION II.
CRIMINAL LAW OF THE STATES.
GUARDIANS OF THE POOR v. GREENE.
Supreme Court of Pennsylvania, 1813.
S Binney, 554.
This was an action of debt in the Common Pleas of Philadel-
phia county, to recover from the defendant the penalty of sixty-
dollars, prescribed by the Act of the 29th of March, 1803, for
refusing to take the oath of office of a guardian of the poor, for the
township of the Northern Liberties, or to undertake the duties of
that office.
The cause was decided below in favor of the defendant in
error.
TiLGHMAN, C. J.' The question in this case is, whether the
defendant in error, an ordained deacon, and an elder in the
Methodist Episcopal Church, is subject to the penalties of the Act
of the 29th of March, 1803, for not serving in the office of a
guardian of the poor, to which he was elected. There is no doubt
but the Commonwealth has a right to insist on the service of every
member of the community, in any capacity in which it may be
thought proper to exact it. But unless the intention is clearly
expressed, it is not to be supposed, that services were meant to be
exacted contrary to ancient usage, and involving incompatible
duties. Every country has its common law. Ours is composed
partly of the common law of England, and partly of our own usages.
appearing for the defendant, the Court would not review, nor draw in doubt
the decision in U. S. v. Hudson.
These two cases have since been frequently relied on as establishing
the doctrine. See U. S. -v. Britton, 108 U. S., 199 (1882); In re Greene, 52
Fed. Rep., 104 (1892).
In U. S. V. Ramsey, Hempstead, 481, it was held that the Act of Con-
gress giving the Circuit Court jurisdiction in murder, did not embrace the
crime of accessory before the fact to murder. — Ed.
'Part of the opinion of Tilghman, C. J., and the concurring opinion of
Yeates, J., and dissenting opinion of Brackenridge, J., are omitted.
6 Cases on Criminal Law.
When our ancestors emigrated from England, they took with them
such of the English principles as were convenient for the situation
in which they were about to place themselves. It required time
and experience to ascertain how much of the English law would
be suitable to this country. By degrees, as circumstances
demanded, we adopted the English usages, or substituted others
better suited to our wants, till at length, before the time of the
revolution, we had formed a system of our own, founded in general
on the English Constitution, but not without considerable variations.
In nothing was this variation greater than on the subject of religious
establishments. The minds of William Penn and his followers
would have revolted at the idea of an established church. Liberty
to all, but preference to none ; this has been our principle, and this
our practice. But although we have had no established church,
yet we have not been wanting in that respect, nor niggards of those
privileges, which seem proper for the clergy of all religious denom-
inations. It has not been our custom to require the services of
clergymen in the offices of constables, overseers of the highways,
or of the poor, jurors, or others of a similar nature. Not that this
exemption is founded on any Act of Assembly, but on an universal
tacit consent. In the nature of things, it seems fit, that those per-
sons who devote their lives to the service of God, and the religious
instruction of their brethren, should be freed from the burden of
temporal offices, which would but distract their attention, and may
be better filled by others. This sentiment is not peculiar to us.
We find it in the English common law, though from motives of
policy restricted perhaps to the established church. It is said by
Lord Coke, in 2 Inst, 3, 4, to be a principle of the ancient com-
mon law, that the clergy shall not be impHcated in secular busi-
ness ; and that if a man holding lands, by virtue of which he is
bound to serve in temporal offices, become an ecclesiastical person
in holy orders, he ought not to- be elected to such office, and if he
is, he may have the king's writ for his discharge. And in the
Register of Writs, 187, and Fitz. N. B., 175, the form of the writ is
to be found. It appears, then, that what the English have applied
to their established church, we, in conformity to our principles of
religious liberty, have granted to the clergy of all professions.
Nor is the privilege confined to common law offices. It is proved
by the cases cited in the argument to which I refer, that the same
Cases on Criminal Law. J
construction has been held with respect to offices created by
statute, in which there is no express exemption of the clergy.
The rule of construction is this : unless the clergy are mentioned,
it shall not be supposed that it was intended to include them. If
we apply this rule to the Act of Assembly in question, the case
will be easily decided. The act directs that a certain number of
substantial householders shall be elected, but is altogether silent
as to any exemptions. We must presume, then, that it was not
intended to include persons who, from ancient usage, were exempt
from this kind of service, oi- who held other offices incompatible
with the duty of a guardian of the poor. Without such presump-
tion, how is it that judges and attorneys at law are privileged ?
They have no express privilege by that or any other law, but in
sound construction they are excepted from the general words of
the act.
My opinion is, that the Court of Common Pleas were right in
their construction of the Act of Assembly, and therefore their
judgment should be affirmed.
JAMES V. COMMONWEALTH.
Supreme Court of Pennsylvania, 1825.
12 Sergeant and Rawle, 220.
This was a writ of error to the Court of Quarter Sessions of
Philadelphia county ; at the September sessions of which court
Nancy James, the plaintiff in error, had been convicted of being a
common scold, and thereupon, on the 29th day of October, 1824,
adjudged "to be placed in a certain engine of correction, called a
cucking, or ducking stool, and being placed therein to be plunged
three times into the water ; to pay the costs of prosecution, and
stand committed till the sentence is complied with." The error
assigned was 'nhat this judgment is illegal."
Swift, for the plaintiff in error.
Pettit, Deputy Attorney-General, for the Commonwealth.
Duncan, J.^ This sentence, we are informed, has created
^ Only extracts from the opinion are printed.
8 Cases on Criminal Law.
much ferment and excitement in the public mind. It is con-
sidered as a cruel, unusual, unnatural, and ludicrous judgment.
But whatever prejudices may exist against it, still, if it be the law
of the land, the court must pronounce judgment for it. But,
as it is revolting to humanity, and is of that description that only
could have been invented in an age of barbarism, we ought to be
well persuaded, either that it is the appropriate judgment of the
common law, or is inflicted by some positive law ; and that that
common law or statutory provision has been adopted here, and is
now in force.
The late Judge Ingersoll, a name respected and honored,
when attorney general, in his report to the legislature in 1813,
slated, that by several acts of assembly " cruel and unnatural pun-
ishments, which tended only to harden and confirm the criminal,
had been abolished for all inferior offences." The sanguinary
code of England could be no favorite with William Penn and his
followers, who fled from persecution. Cruel punishments were not
likely to be introduced by a society who denied the right to touch
the life of man, even for the most atrocious crime. For had they
brought with them the whole body of the British criminal law, then
we should have had the appeal of death, and the impious spectacle
of trial by battle in a Quaker colony ; and it is Worthy of remem-
brance, that the charter of William Penn empowered him, with the
advice and assent of the freemen, to make laws for their own gov-
ernment, and until this was done, the laws of England in respect to
real and personal property, and as to felonies, were to continue the
same. Thus, as to misdemeanors, the common law punishments
were not brought over by the first settlers.
The first body of laws (called the great body of laws) contains
an act passed in 1682, against scolding, imposing the penalty, five
shillings, or three days confinement at hard labor. (Chap. 34.)
The second act, in 1683 (chap. 12), inflicts the same penalty, or
standing one hour in "the most public place, with a gag in the mouth;
and, eleven years after this, in 1693, in the petition of right to
Governor Fletcher, they state that the laws contained in that list
had not been repealed by the King in council and that it had pleased
the King and Queen so tenderly to regard their happy government,
as to confirm their laws and constitutions, so fitly accommodated to
their circumstances, and conclude by earnestly desiring him to
Cases on Criminal Law. 9
•govern them according to these laws, including the laws against
scolding ; and the governor commanded them to be enforced.
These acts continued in force until 1 770, when another act against
scolding passed, inflicting the same penalty, of imprisonment five
•days at hard labor, or to be gagged and stand at some convenient
place, at the discretion of the magistrate. The act of 1770 was
repealed by the Queen in council, but I have not been able to find
the repeal of the acts of 1682 and 1683. It seems to have been the
opinion of the late Judge Bradford, that all in the great body of laws
was repealed, and I would not venture totally to dissent from so high
an authority, though I must confess I think this very doubtful.
Nor do I see how, consistently with the charter, this could other-
wise be repealed, than by act of assembly. If they were not directly
repealed, they were not virtually repealed by the repeal of the act
of 1700. Whatever be the fact, the conclusion is the same, — that
the common law punishment of ducking was not received nor em-
bodied by usage, so as to become a part of the common law of
Pennsylvania. It was rejected, as not accommodated to the cir-
■cumstances of the country, and against all the notions of punish-
ment entertained by this primitive and humane community ; and
though they adopted the common law doctrines as to inferior offences,
yet they did not follow their punishments. One remarkable
instance I will notice. A gross libel in England was sometimes
punished by the pillory ; I believe Mr. Prynne lost both his ears.
Though the offence is the same here, yet the sentence is very dif-
ferent. It is not true that our ancestors brought with them all the
common law offences ; for instance, that of champerty and main-
tenance, this court decided in Stoeverz'. Whitman's Lessee, 6 Binn.,
416, did not exist here. I do not find the rule on this subject more
satisfactorily laid down anywhere than by the Chief Justice, in The
Guardians of the Poor of Philadelphia v. Greene, 5 Binn., 558.
This is a very different question from the common law rules
of real and personal property, — the modes of acquisition and
alienation of estates. For although the reasons of many of those
rules have ceased, yet it might be dangerous, on that account, to
abolish them ; as it would lessen the security of property of titles
to land, which should always be firm and stable ; and by the
charter they were to remain the same as in England, except when
altered by the representatives of the people. But I am far from
lo Cases on Criminal Law.
professing the same reverence for all the degrading and ludicrous
punishments of the early days of the common law. I am far
from thinking that this is an unbroken pillar of the common law,
or that to remove this rubbish would impair a structure which no
man can admire more than I do. But I must confess, I am not
so idolatrous a worshipper as to tie myself to the tail of this dung-
cart of the common law. * * * The courts of our sister States
of New York and Massachusetts, governed by the same common
law as we are, have declared that this strange and ludicrous punish-
ment no longer exists with them.
In considering this question, I own, I have some hesitation in
deciding whether the offence of communis vexatrix exists as
indictable, but I have acceded to the opinion of the Chief Justice
and my brother Gibson ; it is now to be considered as indictable
and punishable as a common nuisance, by fine, or by fine and
imprisonment, at the discretion of the Court, the acts of assembly
being obsolete, and the common law punishment of ducking, not
being received here ; and I join in the hope of a learned antiqua-
rian and jurist of our own country, " that we shall hereafter hear
nothing of the ducking stool, or other remains of the customs of
barbarous ages." Duponceau on Jurisdiction, 96. It is there-
fore the opinion of the court, that the judgment of the Court of
Quarter Sessions be reversed. Judgment Reversed.
RESPUBLICA V. MESCA.
Oyer and Terminer at Philadelphia, 1783.
I Dallas, "jj.
This was an indictment against four Italians for the murder of
Captain Pickles ; and, upon the arraignment of the prisoners, the
Court assigned Ingersol and Swift as counsel for them. These
gentlemen then challenged the a.rTay, and moved for an award of a
ta/es de medietate linguce ; but the Attorney General controverted
the propriety of the motion, and it was twice argued, on the 25th
and 29th of September.
The counsel for the prisoners urged that the Stat, of Edw. 3.,
c. 13, was a beneficial law, encouraging foreigners to come into the
Cases on Criminal Law. ii
country ; that, in practice, it had been extended to Pennsylvania
before the revolution, and sound policy justified its continuance.
In the course of their argument the following authorities were
cited : i Pen. Laws 89, 28 ; Edw. 3, c. 13 ; 4 Bl. Com., 352 ; 2
H. H. P. C, 271-272 ; Dyer, 304; Chart, of Ch., 2 to Penn. ; 2
Wils., 75 ; Salk., 411.
To prove ^he practice, Thomas Clifford, upon his solemn affir-
mation, stated, that in February, 1764, a burglary was committed
in his dwelling house in Philadelphia; that one Brinkloe, being
apprehended upon suspicion, accused William Frederick Ottenreed
whereupon they were both imprisoned and. tried ; and to the best
of the witnesses' recollection, Ottenreed was allowed to have a
moiety of foreigners on his jurj'.
The Attorney General observed that thequestion turned upon
this point — how far the English statutes were extended to Penn-
sylvania? and by what authority they could be extended, whether
exclusively by an act of the Legislature, or, likewise, by the adjudi-
cations of the supreme court ? The sentiment of the foreign jurists
seemed, he said, to be crude and undigested upon this subject ; but
certain principles, which had obtained the authority of a general
assent, might serve as a directory to form an accurate judgment.
He then adverted to several acts of Parliament which did not extend,
as the act of limitations, Jac. 2, the 28 H., 8, respecting pirates
etc., and urged that, by the royal charter, the common law, and
statute law, relating to felonies were extended ; but that statutes
merely relating to the mode of trial did not extend ; on which
account laws were passed in that respect, soon after the settlement
of the province.
With respect to the statute immediately in question, he con-
tended, that it never had been extended by the Legislature, because
it was thought unnecessary, and might often be greatly inconve-
nient ; for in every case where foreigners were tried, the humane
provision of our laws, which allows them counsel, would then be
defeated. A trial per medietatem lingua was never granted to
Indians, or Negroes ; nor is it, indeed, pretended to have taken
place in any more than one instance ; and that, too, rests entirely
on the recollection of a single witness.
The Attorney General cited : 2 Hawk., 420 ; Tri. per Pais,
247 ; Dyer, 357 ; a. Cro. E, 869 ; Smith's History of New York,
12 Cases on Criminal Law.
24, 243; 2 Pen. Laws, 2; i Pen. Laws in App., 318; Votes of
Ass., Vol. I, p. 6, 53 ; 106 id. in App., 11 ; i Pen. Laws, 88, 1 14 ;
Votes of Ass., Vol. 2, p. 22, 211, 234; Robin, view State of
Europe, 395.
The Chief Justice delivered the opinion of the Court as follows :
McKean, C. J. The point before the court has been well
argued ; and, on a full consideration of the subject, we now find
little difficulty in pronouncing our decision. The first Legislature
under the Commonwealth, has clearly fixed the rule respecting the
extension of British statutes by enacting that "such of the statutes
" as have been in force in the late province of Pennsylvania, should
" remain in force, till altered by the Legislature." And it appears in
evidence, that the 28 Edw. 3., c. 13, has been in force in the late
province, since a trial per medietatem linguce was allowed in the
case of a burglary committed by one Ottenreed, in the mansion
house of Mr. Clifford.
Whether it was intended by the act, to which I have referred,
to include only such statutes as were in force, by an express exten-
sion of the Legislature ; or to comprehend, likewise, such statutes
as had been extended by the judgment of the Supreme Court, or
received there in usage, seems to be, in some degree, uncertain.
We know, however, that many statutes for near a century, have
been practiced under in the late province, which were never
adopted by the Legislature ; and that they might be admitted by
usage, and so become in force, was the opinion of the British Par-
liament, declared in a statute passed in the year 1754, enabling
legatees to be witnesses to wills and testaments. If, therefore, the
statute in question has been, by any means, legally in force ; a
necessity is, seemingly, imposed upon us, to grant the challenge to
the array, which has been made on behalf of the prisoners.
But if this was a new case, the judgment of the court would be
different ; for, the reasons which give rise to the 28 Edw. 3, do
not apply to the present government, nor to the general circum-
stances of the country. Prisoners have here a right to the testi-
mony of their witnesses upon oath, and to the assistance of counsel,
as well as in matters of fact, as of law ; which was not the case in
England in the year 1353, when that statute was enacted. We do
not think, indeed, that granting a medietas linguce, will, at all,
contribute to the advancement of justice ; and we know it is a
Cases on Criminal Law. 13
privilege which the citizens of Pennsylvania cannot reciprocally
enjoy, as, at this day, there are no juries in any part of Europe,
except in the British dominions.
On the ground, however, of the precedent which has been
shown, we hold ourselves bound, on this occasion, to allow the
challenge, and to grant a trial per medietatem Ungues.
RESPUBLICA V. ROBERTS.
Supreme Court of Pennsylvania, 1791.
I Yeates, 6.
The defendant was tried at the last Nisi Prius Court for Bucks
county, and a special verdict found by consent. It stated, that he
was an unmarried man, and had been guilty of criminal conversa-
tion with Isabella McGlister, a married woman, her husband being
then and now in full life. And whether the same were punishable
as adultery in him, was the question. He had also been charged
with bastardy, but as the Attorney General had admitted at the
trial that her husband had not been far distant from her, and that
she was not a competent witness to prove the want of access, he
was acquitted of that charge by consent.
Mr. Bradford, Attorney General, contended that the facts
found involved him in the offense of adultery ; that the Act of
Assembly in 1705 did not describe what adultery was, and there-
fore the only point was, what was the received idea of the Legisla-
ture when they passed the law. That the rule of construction, as
settled in i Blackst. Com., 59, was to find out the meaning either
in the common and popular sense, or considered as a technical
term, according to the received sense of the learned in that science.
To establish the common and popular sense of the word, he cited
Johnston's Diet. Voc. Adultery; 20 Chap. Leviticus, verse 10; 19
Chap. Matthew 9 ; 6 Chap. Proverbs, 29 and 32d verses ; where the
word is used as a general violation of the marriage bed, according
to its derivation, " ad ulterius thorum " ascendere. To fix its tech-
nical sense, he cited 2 Inst. 486, 435 ; Cowel's Law Diet. Voc.
Adultery; 4 Blackst. 64, 65, 191; 4 Burr. 2057; Pandects of
the Civil Law, 82; Wood's Inst, of Civil Law, 300, 261 ; 2 Ld.
14 Cases on Criminal Law.
Raym. 802 ; Laws of Connecticut, p. 8, and Espinasse, 430, that
actions of crim. con. are styled in the modern books, actions of
adultery.
Mr. Sergeant, for the defendant, contended that the crime
was different in the civil and canon laws, and cited Encyclopaedia
Voc. Adultery, and that the Act of Assembly particularly describ-
ing that an unmarried woman having a child born of her body shall
be deemed guilty of fornication, could not intend that the offence
of an unmarried man should be greater than that of an unmarried
woman. And that the true mode of fixing the meaning of the
term was by the uniform general practice of courts of justice, who
had proceeded only against married persons as having been guilty
of adultery.
To this the Attorney General replied, that no argument can be
drawn from the practice, as it had received no judicial decision,
and that public prosecutors might proceed against the party offend-
ing for the lesser offence, for a variety of reasons, as he himself
had actually done this term ; and further cited Pailey's Moral
Philosophy, 201.
Per Cur. The single question is, whether an unmarried man
may be guilty of adultery, under the Act of Assembly. Originally
the offence was of temporal jurisdiction, but after the statute of
circutnspecte agatis, it was remitted to the bishop of Norwich, and
through him to the spiritual courts.
Had the case been res Integra, the decision of the court might
be different from what it now is. It is true that practice sub silentio
will not make the law, but it is strong evidence of what the law is.
It having been the constant practice to proceed against unmarried
persons for fornication, though they may have been guilty of crim-
inal conversation with married persons, we will not exaggerate the
offence, nor carry it further than our predecessors have done ; and,
therefore, the court pronounce him guilty of fornication, and fine
him 10/. and the costs, and commit him to the Sheriff of Philadel-
phia county, who always executes the process of the court in banc.
Shippen J. The practice above-mentioned is truly stated from
my personal knowledge for forty-eight years past.^
' Part of this case is omitted.
Cases on Criminal Law. 15
STATE V. PARKER.
Supreme Court of North Carolina, 1884.
91 North Carolina, 650.
Indictment for retailing liquor, tried at Spring Term, 1884,
of Cleveland Superior Court, before MacRae, J.
The defendant was indicted for selling liquor within two and
a half miles of Zion Church in Cleveland county.
The indictment was preferred under the Act of 1883, ch. 166,
§7, which is as follows : " That it shall be unlawful for any person
to sell, or in any manner, directly or indirectly, receive compensa-
tion for any spirituous or other intoxicating liquors in the localities
hereinafter named * * * within two and a half miles of Zion
Baptist Church, in Cleveland county." There are like inhibitions
in sections four, five and six of the act. And in section eight it
is provided " that any person violating the provisions of sections
four, five and six of this act, shall be deemed guilty of a misde-
meanor."
The defendant contended that, inasmuch as the seventh sec-
tion was omitted in the enumeration of the sections of the act, the
violation of which was made indictable by the eighth section, the
violation of that section was not the subject of a criminal prose-
cution, and that therefore the defendant ought to be acquitted.
His Honor did not concur in this view, but held that " as the
law made it unlawful to sell liquor as aforesaid, it was a misde-
meanor to violate the same, though not so expressly declared, and
charged the jury accordingly.
The defendant was convicted and appealed from the judg-
ment pronounced.
Attorney General, for the State.
Messrs. Gidney & Webb, for defendant.
Ashe, J. There is no error in the charge given by his
Honor. No doubt the seventh section was omitted to be men-
tioned in the eighth section through inadvertence ; or, it may be,
that it was a mistake in the printer. Be that as it may, it can
make no difference, for there can be no doubt, as his Honor held,
that the defendant is indictable at common law.
i6 Cases on Criminal Law.
If a statute prohibit a matter of public grievance, or com-
mand a matter of public convenience, all acts or omissions contrary
to the prohibition or command of the statute, being misdemeanors,
at common law, are punishable by indictment, if the statute
specify no other mode of proceeding. Arch. Cr. Law 2 ; 2
Hawk., ch. 25, § 4. There is no other mode of proceeding speci-
fied in the act ; ergo, the defendant is indictable at common law..
Let this be certified, &c.
No error. Affirmed.
STATE V. PULLE.
Supreme Court of Minnesota, 1866.
12 Minnesota, 164.
Wilson, Ch. J.' The common law so far as it is applicable
to our situation and government, is, as a general rule, the law of
this country. Every State, with perhaps one exception, has adopted
it, either tacitly or by express statutory enactment. See i Kent's
Commentaries, 470-3, note and cases in note. That it is the law of"
this State, controlling both the rights and the remedies of parties
in actions between individuals, either on a contract or for a tort,
cannot be doubted, for the courts have recognized and acted on
this fact ever since the organization of our territorial government,
and we find no evidence which satisfies us that either the State or
territory intended to repudiate the common law as a source of juris-
diction in either criminal or civil cases. It having been adopted in
civil cases, the presumption certainly is that it was adopted as an
entirety, so far as it is not inconsistent with our circumstances, or
statutory or constitutional law. Nor do the laws in force in Wis-
consin territory at the date of the admission of the State of Wisconsin
(which, by our organic act were declared to be valid and operative
in Minnesota territory), rebut this presumption. There is nothing
in these laws which shows that the territory of Wisconsin abrogated
or repealed the common law as to crimes, but on the contrary, we
think they show that it was recognized and adopted in that terri-
tory. That our statutes expressly abolish common law offenses, is.
'The opinion only is printed.
Cases on Criminal Law. 17
not pretended. A statute which is clearly repugnant to the com-
mon law must be held as repealing it, for the last expression of the
legislative will must prevail. Or we may admit, for the purposes of
this case, that when a new statute covers the whole ground occupied
by a previous one, or by the common law, it repeals, by implication,
the prior law, though there is no repugnancy. Beyond this the
authorities do not go in sustaining a repeal of the common law by
implication. On the contrary, it is well settled that where a statute
does not especially repeal or cover the whole ground occupied by
the common law it repeals it only when, and so far as directly and
irreconcilably opposed in terms. See i Bish. Cr. Law, 3ded.,sec.
195 to 200, and cases cited in notes to said sections.
Our statutes fall far short of covering the whole field of com-
mon law crimes. It is not pretended that conspiracy is, by them,
made a crime, and we think it very clear that libel is not, and
many other instances might be added. We think, therefore, that
they do not, by implication, abolish these crimes. But further than
this, we think our statutes clearly recognize the existence of com-
mon law offenses. Sec. 2, chapter 87, Comp. Stat., reads as fol-
lows : ****'! Crimes and public offenses and criminal
proceedings are modified as prescribed in these statutes." The
Revised Statutes were adopted in 185 1, and the language above
quoted was added as an amendment in 1852. It is perhaps true
that this amendment did not change the meaning of the statutes,
but legislators frequently, and properly, make use of language
which, strictly speaking, is unnecessary, out of abundant caution,
and for the purpose of making clear what otherwise might, in the
minds of some, admit of doubt. We think, in this view, the Legis-
lature must have used the language above quoted, to show that
our statutes, as to crimes, were intended merely as a modification,
and not as an entire repeal, or abrogation of the common law.
This seems to us the fair and natural meaning of the language, and
any other construction suggested seems forced and unauthorized.
Section 34 of chap. 90 of said statutes reads : " Every person who
shall be convicted of any gross fraud or cheat, at common law,
shall be punished," &c. Sec. 5, chap. 98, ib., reads : " Every
person who shall become an accessory after the fact, to any felony,
either by common law, or by any statu,te made, or which shall
hereafter be made, may be indicted," &c. Our statutes, in no
i8 Cases on Criminal Law.
place, declare that any act shall constitute the crime of libel, or
that such crime shall be punished, yet they provide as to what
evidence may be given, and as to the form and substance of the
indictment in prosecutions for such crime. Comp. Stat. 734, sec.
6 ; ib. 756, sec. 3 ; ib. 760, sec. 17. These sections are an admis-
sion, or recognition by the Legislature of the fact that common law
offenses may be punished in this State. This conclusion is in
accordance with the views entertained by the courts generally
throughout the United States. See authorities cited in note to
Section 36, i Bishop Cr. Law, 3d ed.
Ohio seems to be an exception to this general rule, but we
have carefully examined the statutes of that State, and do not find
that they, like our statutes, recognize the existence of common law
offenses. The cases cited from that State can, therefore, not be
held as opposed to the decision arrived at in this case. The case
of Estes V. Carter, 10 Iowa, 400, holds, that no common law offense
not recognized by the criminal statutes of that State will be treated
or punished as a crime by the courts. The decision is based on
two grounds ; 1st, the peculiar wording of the Constitution of that
State ; and, 2d, that the statutory offenses so nearly cover all the
common law offenses, that it is reasonable to infer that those which
were omitted were intended to be excluded. If the statutes of that
State, to which we have not had access, are similar to ours, we
cannot admit that the second ground on which the decision is based,
is tenable, for it is certainly a well-settled rule, that statutes are not
to be construed as repealing the common law beyond their words^
or the clear expression of their provisions. Beyond this, no
admitted rule of interpretation permits us to presume an intention
to repeal. See authorities above cited.
There is a remark made by the court in the case of Benson v.
State, 5 Minn., 21, which the counsel for the defendant refers to
in support of his view, but the point was not considered or decided
by the court in that case. This remark deserves, and has received,
the consideration due to the views of the learned judge who deliv-
ered that opinion. Whether it would be wise for the Legislature to
repeal the common law as a source of jurisdiction in criminal mat-
ters, it is not for us tQ determine.
If common law crimes are suspended or abolished by our
statutes, so are "criminal proceedings "; but the Legislature, by the
Cases on Criminal Law. 19
express and particular repeal of certain criminal practice and
proceeding (Comp. Stat, p. 735, sec. 14; ib., p. 785, sec. 37),
clearly indicated that they did not consider the general statute as
affecting such repeal. The gist of this offense is the unlawful con-
federation, and it is not necessary to prove an overt act in
pursuance of it. Commonwealth v. Judd, 2 Mass., 329. The
exceptions are overruled.
Berry, J. — I dissent. In my judgment no offenses at com-
mon law are offenses in this State, except such as as are specifi-
cally recognized by our statutes.'
^The common law in so far as it determines what acts are crimes is not in
force in the following states . Indiana — Jones 7/. St., 59 Ind., 229 (1877);
Iowa — Estes v. Carter, 10 Iowa, 400 (i860); Kansas — St. v. Young, 55 Kans.,
349 (1895) ; Michigan — In re Lamphere, 61 Mich., 105 (1886) ; Ohio —
Smith V. St., 12 Ohio St., 466 (1861) ; Oregon — St. v. Gaunt, 13 Ore., 115
< 1 885). —Ed.
Ecclesiastical Offences. — It is said in Grisham & Ligan v. State, 2
Yerger, p. 595, (1831): "But let it be understood that the temporal courts
in England have no cognizance of the crime of adultery or fornication, when
secret and private and confined to single instances, yet they are not thereby
legalized, or rendered dispunishable, as not being offenses ; they continue
offenses there still, but their cognizance is transferred and assigned to the
spiritual court, who punish according to the rules of the canon law. It cannot
follow as a consequence, that an offense which is common to both the law of
England and this State, and is animadverted upon by the law of England,
and punished by the spiritual court there, shall escape the like animadversion
of the law and punishment here, because we have not a spiritual court ; but
it rather follows from analogy, that our county courts of pleas and quarter
sessions have the jurisdiction in these matters, as we find that matters, the
proper tribunal of which was the spiritual court in England, are in this
State, when not repugnant to our Constitution and form of government,
assigned to the county courts, as the probate of wills and testaments, the
granting of letters of administration, &c.' '
The great majority of the authorities, however, hold that offences cogniz-
able only in the spiritual courts in England, cannot be punished here except
by statute. — Ed.
20 Cases on Criminal Law.
Chapter II.
The Elements of Crime.
SECTION I.
UNION OF INTENT AND ACT.
YOES V. STATE.
Supreme Court of Arkansas, 1848.
9 Arkansas, 42.
Enos Yoes was indicted in Washington Circuit Court for an
assault and battery upon James C. Hughes, He was tried on the
plea of not guilty, at the May Term, 1847, before the Hon. Wm. W.
Floyd, Judge, convicted and fined ten dollars.^
Johnson, C. J. The Circuit Court manifestly erred in giving
the first instruction asked by the State. The instruction is, that
if the jury believe from the evidence that the defendant went to
the meeting-house yard and called Hughes out for the purpose of
having a difficulty with him, they should find him guilty. A crime
or misdemeanor consists in a violation of public law, in the com-
mission of which there must be a union or joint operation of act
and intention or criminal negligence. See ist sec. of chap. 44 of
the Revised Statutes. The mere fact of going to a place with the
intention of doing an unlawful act, will not of itself subject the
party to the punishment denounced against such act, unless he also
.carries his intention into effect. If the defendant below actually
made an assault upon Hughes in pursuance of his preconceived and
settled intention, then it was that the motives, which induced him
to go to the place where Hughes was, might have been legitimately
inquired into in aggravation of the fine, but could not under any
state of case have furnished conclusive evidence of his guilt. No
valid objection is perceived to the last instruction. But for the
error in giving the first, the judgment must be reversed. .
' The evidence and charge of the court are omitted.
Cases on Criminal Law. 21
SECTION II.
OFFENCES AGAINST PUBLIC JUSTICE AND
AUTHORITY.
ANONYMOUS.
King's Bench, 1686.
3 Modern, 52.
One was indicted for the drinking of an health to the pious
memory of Stephen College, who was executed at Oxford for high
treason. He was fined one thousand pounds, and had sentence to
stand in the pillory, and was ordered to find sureties for his good
behavior.'
REX V. DARBY.
King's Bench, 1687.
3 Modern, 139.
The defendant was indicted for speaking of scandalous words
of Sir John Kerle, a justice of the peace, viz : " Sir John Kerle is
a buffle-headed fellow, and doth not understand law ; he is not
fit to talk law with me ; I have baffled him, and he hath not done
my client justice." This is a scandal upon the government, and it
is as much as to say that the king hath appointed an ignorant man
to be a justice of peace, for which an indictment will lie.^ And
of that opinion was the whole Court, and gave judgment
accordingly.'
' See also, absolving impenitent traitors, Rex v. Cook, Comb. 382
(1696). — Ed.
^ Part of this case is omitted,
'Accord: Anon. Comb. 46 (1688); Rex v. Collier, i Wils., 332
(1752); but see Reg. v. Wrightson, 11 Mod. 166 (1708); Rex v. Weltje, 2
Camp., 142(1809). — Ed.
22 Cases on Criminal Law.
PENNSYLVANIA v. MORRISON.
County Court of Allegheny, 1795.
Addison, Pa., 2^^.
These men were indicted for having, on i8th August, 1794,
unlawfully, riotously, and routously assembled together, to disturb
the peace, and, in Market Street in Pittsburg, raised a pole or
standard, called a liberty-pole, in defiance of the laws of the State of
Pennsylvania, and of the United States, and as an indignity and insult
to the Honorable James Ross, Jasper Yeates, and William Bradford,
Esquires, commissioners on behalf of the United States of America,
and the Honorable Thomas McKeah and William Irwin, Esquires,,
commissioners on behalf of the State of Pennsylvania, to confer
with the citizens of the counties west of the Alleghany mountains ;
to the great disturbance of the peace, and to the ill example of
others.^
President. Pole raising was a notorious symptom of dissatis-
faction, and the exhibition of this, in the only part of the country
where government was supposed to have strength, must have made
an impression very unfavorable to the whole countiy, promoted
violence in the people here, and induced force on the part of the
government.
All the evidence of their acting under duress, is their saying so.
It is, at least, as probable, that this was a cover for their real motives,
an opposition to the civil authority. Why did not these men sign
the amnesty, when almost every man besides in the town signed it ?
They surely refrained not from a consciousness of innocence. It
is somewhat singular, if danger then existed, that the only men in
this town anxious for its safety, were men of little or no property
in it ; and that then all the men of property were against this
measure. When there was real danger, all the town went to Brad-
dock's Field.
The act of raising a pole in the street is itself unlawful, inde-
pendent of any other ill intention. The probability is that the
intention was an unlawful opposition to the government, and that
the excuse was feigned to cover their real designs.
Verdict guilty, except as to White and Mc Williams.
^ Part of this case is omitted.
Cases on Criminal Law. 23
REX V WILLIAMS.
King's Bench, 1762.
3 Burrows, 13 17.
An information was granted by the Court against the defend-
ants, as justices of the peace for the borough of Penryn, for re-
fusing to grant licenses to those publicans who voted against their
recommendation of candidates for members of Parliament for that
borough. It appeared that they had acted very grossly in this
matter, having previously threatened to ruin these people, by not
granting them licenses, in case they should vote against those
candidates whose interest those justices themselves espoused, and
afterwards actually refusing them licenses upon this account only.
And Lord Mansfield declared that the Court granted this infor-
mation against the justices, not for the mere refusing to grant
the licenses (which they had a discretion to grant or refuse, as they
should see to be right and proper), but for the corrupt motive of
such refusal, for their oppressive and unjust refusing to grant them,
because the persons applying for them would not give their votes
for members of Parliament as the justices would have had them. ^
STATE V. ELLIS.
Supreme Court of New Jersey, 1868.
33 New Jersey Law, 102.
The opinion of the court was delivered by
Dalrimple, J.^ The indictment in this case was removed
into this court by certiorari to the sessions of Hudson. It sets
forth in substance, in language sufficiently plain and intelligible,
that application having been duly made to the common council of
Jersey City for leave to lay a railroad track along one of the public
■Accord : C. v. Alexander, 4 Hen. and M. 522 (1808) ; corruption in
office, C. V. Callaghan, 2 Va. Cas. 460 (1825); being intoxicated while in
discharge of office. — Ed.
^ The opinion only is printed.
24 Cases on Criminal Law.
streets of that city, the defendant wickedly and corruptly offered
to one of the members of said common council the sum of fifty
dollars to vote in favor of said application. Upon return of the
certiorari, a motion was made to quash the indictment, on the
ground that the facts set forth do not constitute a crime.
It is said that the common law offence of bribery can only be
predicated of a reward given to a judge or other official concerned
in the administration of justice. The earlier text writers thus
define the offence : " Where any man in judicial place takes any
fee or pension, robe or livery, gift, reward or brocage, of any
person, that hath to do before him in any way, for doing his
office, or by color of his office, but of the king only, unless it be
meatand drink, and that of small value." 3 Inst, 145. The defi-
nition in 4 Blackstone'sCom., 139, is to the same effect. HaWkins,
in his Pleas of the Crown, Vol. i, p. 312, gives, substantially, the
same description of the offence, but adds : "Also, bribery signifies
the taking or giving of a reward for offices of a public nature."
The later commentators, supported, as I think, by the adjudged
cases, however, maintain the broader doctrine, that any attempt to
influence an officer in his official conduct, whether in the execu-
tive, legislative, or judicial department of the government, by the
offer of a reward or pecuniary consideration, is an indictable
common law misdemeanor. 3 Greenleaf's Ev., § 71 ; Bishop on
Criminal Law, Vol. i,, § 95, and riotes ; i Russell on Crimes, 156.
The case of Rex v. Vaughan, 4 Burn, 2494, arose upon motion
for an information for a misdemeanor against the defendant for
offering money to the Duke of Grafton, First Lord of the Treasury,
to procure the defendant's appointment by the Crown to an office.
Lord Mansfield, in his opinion in that case, says : " If these trans-
actions are believed to be frequent, it is time to put a stop to them.
A minister, trusted by the king to recommend fit persons to
offices, would betray that trust, and disappoint that confidence, if
he should secretly take a bribe for that recommendation." The
motion was granted. In the case of Rex v. Plympton, 2 Lord
Raymond, 1377, the court held that it was an offence to bribe
persons to vote at election of members of a corporation. Many
other cases might be cited in support of the general proposition
laid down by the later text writers above referred to. The cases
will, however, all be found collated in 2d Bishop's Criminal Law, in
Cases on Criminal Law. 25
the notes to § "j^ and J^. Indeed, the authorities seem to be all
one way. Neither upon principle nor authority can the crime of
bribery be confined to acts done to corrupt officers concerned in
the administration of justice. If in the case now before us, it was
no crime for the defendant to offer, it would have been no crime
for the councilman to accept the bribe. The result would, there-
fore, be that votes of members of council on all questions coming
before them, could be bought and sold like merchandise in the
market. The law is otherwise. The common law offence of
bribery is indictable and punishable in this State. Our statutes
against bribery merely define and fix the punishment for the
offence, in cases of bribery of judicial officers and members of the
legislature ; they do not repeal or abrogate, or otherwise alter the
common law.
It is contended, in the next place, that the facts set forth in the
indictment constitute no offence, inasmuch as the common council
had not jurisdiction to grant the application for which the vote
was sought to be bought. In my opinion, it is entirely immaterial
whether council had or had not jurisdiction over the subject
matter of the application. If the application was, in point of fact,
made, an attempt to procure votes for it by bribery was criminal.
The offence is complete when an offer of reward is made to influ-
ence the vote or action of the official. It need not be averred,
that the vote, if procured, would have produced the desired result,
nor that the official, or the body of which he was a member, had
authority by law to do the thing sought to be accomplished.
Suppose an application made to a justice of the peace, in the court
for the trial of small causes, for a summons in case of replevin, for
slander, assault and battery, or trespass, wherein title to lands is
involved : over these actions a justice of the peace has no juris-
diction, and any judgment he might render therein, would be
coram non judicc and void ; yet, I think, it can hardly be con-
tended, that a justice thus applied to may be offered, and with
impunity accept a reward, to issue a summons in any case without
his jurisdiction. If the common council of Jersey City had not
authority to grant the application referred to, the act of the
defendant in endeavoring to procure the grant asked for was only
the more criminal, because he sought, by the corrupt use of
money, to purchase from council an easement which they had no
26 Cases qn Criminal Law.
authority to grant. He thereby endeavored to induce them tc
step beyond the line of their duty, and usurp authority not com-
mitted to them. The gist of the offence is said to be the tendency
of the bribe to pervert justice in any of the governmental depart-
ments, executive, legislative, or judicial. 2 Bishop's Criminal Law,.
§ 96, Would it not be a plain perversion of justice, to buy the-
votes of councilmen in favor of a surrender of the streets of the
city, for the purposes of a railroad, when such surrender' is unau-
thorized by law ? The rights of the citizens of the municipaUty
thus corruptly tampered with and bargained away, might be-
regained after a long and expensive litigation, or in some other
mode ; nevertheless, bribery and corruption would have done, to-
some extent at least, their work, and the due course of justice have
been disturbed. But I am not prepared to assent, as at present,
advised, to the proposition that the common council could not
properly entertain the application. They were asked by a char-
tered railroad company of this State, having its terminus in Jersey-
City, to consent that a railroad track might be laid along one of the
public streets of that city. It is not pretended that any legislative-
authority to lay such track had been obtained. The railroad company-
could not, under these circumstances, lawfully appropriate to its-
use one of the public streets of the city without the consent of the
city, which has full control over all public streets within the city
limits. Laws of 1851, p. 406, § 6.
Whether or not the common council has the power, with or
without legislative sanction, to grant the use of a public street to
a railroad company for the uses of the railroad, it is, I think, clear
that no such use can be made of the streets, without the consent,
of the city, in the absence of a legislative grant to that effect.
Nor is it material whether the railroad company which
applied for the privilege, had the power under its charter to lay
the track. Application had been duly made for that purpose, and
was pending. An attempt to bribe a member of council to vote
upon it, whether such attempt was made after or before the intro-
duction of an ordinance or resolution granting the privilege asked,,
comes within the general law against bribery. Whether the
common council had authority to make the grant, or the railroad
company the power to avail itself of its benefits, if made, or
whether the offer of a bribe was before or after the application in
Cases on Criminal Law. 27
due course of proceeding, had been embodied in an ordinance
or resolution, is immaterial. The offer of anything of value in
corrupt payment or reward for any official act, legislative, execu-
tive, or judicial, to be done, is an indictable offence at the
common law.
The objections taken are not tenable, and the motion to quash
must be denied.
Motion denied. ^
COMMONWEALTH v. McHALE.
Supreme Court of Pennsylvania, 1881.
97 Pennsylvania, 407.
Paxson, J.^ — The indictment against Anthony McHale con-
tains three counts. In the first count it is charged that " intending
to procure a false count and return of the votes cast by the elec-
tors," etc., he did " make false and fraudulent entries in the books
kept by the clerks at said election in said election district, which
books are commonly known as the list of voters, of the names of
divers persons, to wit, twenty-one persons whose names are as fol-
lows," etc. The second count charges that, with like intent, he
did " deposit among the ballots CEist at said election in said election
district by the electors voting thereat, false and fraudulent ballots
of a large number, to wit, twenty-one ballots," etc. The third
count charges that with hke intent he did, " with the connivance of
the election officers holding said election, undertake and assume to
count the ballots cast by the electors voting at said election in said
election district, and did falsely, fraudulently, maliciously and
unlawfully make a false and fraudulent count of said ballots as to
make it appear that two hundred and eleven votes were deposited
for one Adolph W. Schaick for the office of district attorney, when
in truth and in fact he did not receive more than one hundred and
eighty-five votes," etc.
Some of these offences, perhaps all of them, are indictable
under the Act of 1839, and its supplements, when committed by
election officers. The defendants were not election officers ; at
least, they were not indicted as such.
1 Accord : Walsh v. P., 65 111., 58 (1872).— Ed.
'^ Part of the opinion is omitted.
28 Cases on Criminal Law.
It must be conceded that offences which strike at the purity
and fairness of elections are of a grave character. Are they indict-
able at the common law ? This is a serious and at the same time
comparatively new question. In considering it, we have little in the
way of authority to guide us.
It was assumed by the learned counsel for the defendants that
an indictment will not lie at common law for such acts. In their
printed argument they dismiss the subject with this brief remark :
" Offences against the. election laws are unknown to the common
law ; they are purely and exclusively of statutory origin." It may
safely be admitted that if the question depends upon the fact
whether a precise definition of this offence can be found in the text
books, or perhaps in the adjudged English cases, the law is with
the defendants. This, however, would be a narrow view, and we
must look beyond the cases and examine the principles upon which
common law offences rest. It is not so much a question whether
such offences have been so punished as whether they might have
been.
What is a common law offence ?
The highest authority upon this point is Blackstone. In chap.
13, of vol. 4, of Sharswood's edition, it is thus defined : "The last
species of offences which especially affect the Commonwealth are
those against the public police or economy. By the public police
and economy I mean the due regulation and domestic order of the
kingdom, whereby the individuals of the State, like members of a
well-governed family, are bound to conform their general behavior
to the rules of propriety, good neighborhood and good manners,
and to be decent, industrious and inoffensive in their respective
stations. This head of offences must therefore be very miscella-
neous, as it comprises all such crimes as especially affect pubhc
society, and are not comprehended under any of the four preceding
series. These amount some of them to felony, and others to mis-
demeanors only." The learned author then proceeds to define
certain offences of both classes which are among the crimes against
the public police or economy. The felonies I will omit. The mis-
demeanors are : i. Common or public nuisances, of which a large
variety are given, commencing with obstruction to public highways
and ending with common scolds. 2. Idleness. 3. Sumptuary
laws. 4. Gaming. 5. Destroying game. These, as the text
Cases on Criminal Law. 29
shows, are but illustrations. A large number of these and other
common law offences are now, and have for many years been regu-
lated by statute in England. But in most instances the statute is
merely declaratory of the common law, the object being to define
the crime with greater accuracy or to increase the punishment.
The above quotation from Blackstone is in harmony with other
text writers. Bishop, in his work on Criminal Law, vol. i., sects.
358 and 368 (ist ed.) says : " The government requires its subjects
to do more than simply abstain from attempting its overthrow. It
requires them to give, when called upon, their active assistance to
it, and at all times to refrain from casting obstructions in the way
of its several departments and functions. Therefore every viola-
tion of these duties, being sufficient in magnitude for the law to
regard, is criminal. * * * We se'e it to be of the highest import-
ance that persons be elected to carry on the government in its'
various departments, and that in every case a suitable choice be
made. Therefore any act tending to defeat these objects, as forci-
bly or unlawfully preventing an election being held, bribing or
corruptly influencing an elector, casting more than one vote, is pun-
ishable under the criminal common law." Mr. Wharton in his work
on Criminal Law, vol. i., sec. 6 (6th ed.), places the giving of more
than one vote at an election as among the misdemeanors at common
law. The Supreme Judicial Court of Massachusetts in two cases
has recognized the same doctrine. The first was Commonwealth v.
Silsbee, 9 Mass., 417, which was an indictment charging that the
defendant did " wilfully, fraudulently, knowingly and designedly
give in more than one vote for the choice of selectmen of the said
town of Salem at one time of balloting," etc. After conviction the
defendant moved in arrest of judgment that there was no statute
covering the offence. It was said by the Court : " There cannot
be a doubt that the offence described in the indictment is a mis-
demeanor at common law. It is a general principle that where a
statute, gives a privilege, and one wilfully violates such privilege,
the common law will punish such violation. In town meetings
every qualified voter has equal rights, and is entitled to give one
vote for every officer to be elected. The person who gives more
infringes and violates the rights of other voters, and for this offence
the common law gives the indictment." The other case is Com-
monwealth V. Hoxey, 16 Mass., 385. The defendant was charged
30 Cases on Criminal Law.
with disturbing a town meeting assembled to make choice of town
■officers for the political year then ensuing, and that the said de-
fendant, " intending as much as in him lay to prevent the choice
of said selectmen according to the will of the electors and to
interrupt the freedom of election, unlawfully and disorderly did
openly declare that the old selectmen should not be chosen, and
attempted repeatedly to take from the box, which contained the
ballots of the electors, the votes of the electors," etc. The defend-
ant pleaded guilty to the indictment, and moved in arrest of judg-
ment ; "because the said indictment purports to be founded upon
a statute law of the Commonwealth ; whereas there is no such
statute in the State making the facts set forth in the indictment
an offence against the Commonwealth ; and because the facts set
forth in the indictment do not amount to an offence at common
law." The Courts, after admitting there was no statute to meet the
case, proceeded to say : " The remaining question is, do the facts
charged amount to an offence at common law ? On this question
we entertain no doubts. Here was a violent and rude disturbance
of the citizens, lawfully assembled in town meeting, and in the actual
exercise of their municipal rights and duties. The tendency of the
■defendant's conduct was to a breach of the peace, and to the preven-
tion of elections necessary to the orderly government of the town, and
due management of its concerns for the year. It is true that the
■common law knows nothing perfectly agreeing with our municipal
assemblies. But other meetings are well known and often held in
England, the disturbance of which is punishable at common law as a
misdemeanor. In this Commonwealth town meetings are recognized
in our Constitution and laws ; and the elections made and business
transacted by the citizens at those meetings lie at the foundation of
our whole civil polity. If then there were no statute prohibiting dis-
orderly conduct at such meetings, an indictment for such conduct
might be supported." While the Court put this case partly upon
the ground that the defendant's conduct tended to a breach of the
peace, it is evident the principal reason was the interference with
the rights of the electors, which, as the learned judge truly said
" lie at the foundation of our civil polity," and it may be safely
asserted that every fraud upon the ballot tends directly to a breach
of the public peace if not to revolution and civil war.
We are of opinion that all such crimes as especially affect
Cases on Criminal Law. 31
public society are indictable at common law. The test is not whether
precedents can be found in the books, but whether they injuriously
•affect the public police and economy.
It needs no argument to show that the acts charged in these
ndictments are of this character. They are not only offences
which affect public society, but they affect it in the gravest manner.
An offence against the freedom and purity of elections is a crime
against the nation. It strikes at the foundations of republican
institutions. Its tendency is to prevent the expression of the
will of the people in the choice of rulers, and to weaken the
public confidence in elections. When this confidence is once
destroyed the end of popular government is not distant. Surely,
if a woman's tongue can so far affect the good of society as to
demand her punishment as a common scold, an offence which
involves the right of a free people to choose their own rulers in the
manner pointed out by law is not beneath the dignity of the com-
■mon law, nor beneath its power to punish. The one is an annoy-
.ance to a small portion of the body poUtic ; the other shakes the
■social fabric to its foundations.
We are of opinion that the offences charged in these indictments
are crimes at common law. We regard the principle thus an-
nounced as not only sound but salutary. The ingenuity of poli-
ticians is such that the offences agaijist the purity of elections are
•constantly liable to occur which are not specifically covered by
statute. It would be a reproach to the law were it powerless
to punish them.
It follows from what has been said that it was error to quash
the indictments.
The judgment is reversed in each case, and a procedendo
awarded.
32 Cases on Criminal Law.
STATE V. DOUD.
Supreme Court of Connecticut, 1829.
7 Connecticut, 385.
Peters, J.^ By the common law, all immoral acts, which
tend to the prejudice of the community, are offences, and pun-
ishable by courts of justice. They are denominated crimes and
misdemeanors. The former comprehend the more aggravated
offences, which are nearly allied and equal in guilt to felony, whereof
the superior court formerly assumed jurisdiction ; the latter, in-
ferior offences, whereof the superior and inferior courts have occa-
sionally taken cognizance. But now, by statute, the Superior Court
alone has jurisdiction of all offences at common law. Stat. 29. ed.
1784; 172 : ed. 1821 ; 191 ; Sess. 1828; Knowles v. State, 3 Day
103; 2 Swift's Syst. 366, Swift's Dig. 257; State v. Howard, i
Com. Rep. 475; Rex v. Higgins 2 East 5.
By the ancient common law, prison breaches were felonies, if
the party were lawfully imprisoned, for any cause whatever,
whether civil or criminal, and whether he were actually within the
walls of a prison, or in the stocks, or in the custody of a person
who had lawfully arrested him. 2 Hawk. P. C, c. 18. s. i. And
it hath been holden, by all the judges of the King's Bench, that
though a prisoner departs from prison, with the keeper's license, it
is an offence punishable as well in the prisoner as in the keeper.
Hobert and Stroud's case, Cro. Car. 209. The same doctrine is
laid down by Sir William Blackstone, 4 Com. 129; and it is sanc-
tioned by the late Ch. J. Swift, 2 Sw. Dig. 325. The escape of a
person lawfully arrested, by eluding the vigilance of his keepers,
before he is put in hold or in prison, is an offence against public
justice ; and the party himself is punishable by fine and imprison-
ment. For however strong the natural desire of liberty may be,
yet every man is bound to submit himself to the restraints of the
law. 2. Sw. Dig., 325, 4 Bla. Com., 129.
I am, therefore, of opinion, that the information is sufficient ;
and as the prisoner is not charged with breaking the prison, or
any other actual violence, in effecting his escape, I advise, that he
^ The opinion only is printed.
Cases on Criminal Law. 33
be subjected to the usual common law punishment, fine and im-
prisonment, one or both, at the discretion of the Superior Court,
not exceeding the punishment from which he escaped.
The other Judges were of the same opinion, Williams, J. in-
timating some doubts.
Information sufficient}
SECTION III.
OFFENCES AGAINST THE LAW OF NATIONS.
RESPUBLICA V. De LONGCHAMPS.
Oyer and Terminer of Philadelphia, 1784.
I Dallas, III.
McKean, Chief Justice.^ Charles-Julian De Longchamps: —
You have been indicted for unlawfully and violently threatening
and menacing bodily harm and violence to the person of the
Honorable Francis-Barbe de Marbois, Secretary to the Legation
from France, and Consul General of France to the United States
of America, in the mansion house of the Minister Plenipotentiary
of France ; and for an assault and battery committed upon the
^ Accord : Disobeying an order of a justice, Rex v. Gilkes, 3 Car. and
P., 52 (1827); rescue, St. v. Murray, 15 Me., 100(1838); refusal to assist
officer, Comfort v. C, 5 Whart., 437 (1840); preventing attendance of witness
or juror, SL v. C^penter, 20 Vt., 9 (1847); refusing to accept office. Attorney
General v. Read, '2 Mod., 299 (1678) ; but see St. v. McEntyre, 3 Ire., 171
(1842). — Ed.
^ Part of this case is omitted.
Other offences against public justice are :
Barratry. "Abarrater is a common mover, exciter, or maintainer of
suits or quarrels, either in court, or in the country." Hawk, P. C. (Curw. ed.)
474; see C. V. M'Culloch, 15 Mass., 227 (18 18).
Maintenance. "An unlawful taking in hand, or upholding of quarrels
or sides, to the disturbance or hindrance of common right." Hawk, P. C.
(Curw." ed.), 454; see Key v. Vattier, i Ohio, 132 (1823).
Champerty. "The unlawful maintenance of a suit, in consideration of
sonie bargain to have part of the thing in dispute, or some, profit out of it.'-
Hawk, P. C. (Curw. ed.), 463; see Thompson v. Reynolds, 73 111., 11 (1874)
34 Cases on Criminal Law.
said secretary and consul, in a public street in the city of Philadel-
phia. To this indictment you have pleaded that you were not
guilty, and for trial put yourself upon the country. An unbiased
jury, upon a fair trial and clear evidence, have found you guilty.
The first crime in the indictment is an infraction of the law of
nations. This law, in its full extent, is part of the law of this
State, and is to be collected from the practice of different nations,
and the authority of writers.
The person of a public minister is sacred and inviolable.
Whoever offers any violence to him not only affronts the sovereign
he represents, but also hurts the common safety and well-being of
nations ; he is guilty of a crime against the whole world.
All the reasons which establish the independency and inviola-
biUty of the person of a minister, apply likewise to secure the
immunities of his house. It is to be defended from all outrage ; it
is under a peculiar protection of the laws. To invade its freedom
is a crime against the State and all other nations.
The comites of a minister, or those of his train, partake also
of his inviolability. The independency of a minister extends to
all his household. These are so connected with him, that they
enjoy his privileges and follow his fate. The secretary to the
embassy has his commission from the sovereign himself. He is
the most distinguished character in the suite of a public minister,
and is in some instances considered as a kind of public minister
himself. Is it not, then, an extraordinary insult to use threats of
bodily harm to his person in the domicile of the minister plenipo-
tentiary? If this is tolerated, his freedom of conduct is taken
away, the business of his sovereign cannot be transacted, and his
dignity and grandeur will be tarnished.
You, then, have been guilty of an atrocious viloation of the
law of nations ; you have grossly insulted gentlemen, the peculiar
objects of this law (gentlemen of amiable characters, and highly
esteemed by the government of this State) in a most wanton and
unprovoked manner. And it is now the interest as well as duty of
the government to animadvert upon your conduct with a becoming
severity — such a severity as may tend to reform yourself, to deter
others from the commission of the like crime, preserve the honor
of the State, and maintain peace with our great and good ally, and
the whole world.
Cases on Criminal Law. 35
A wrong opinion has been entertained concerning the conduct
of Lord Chief Justice Holt and the Court of King's Bench, in
England, in the noted case of the Russian Ambassador. They
detained the offenders, after conviction, in prison, from term to
term, until the Czar Peter was satisfied, without ever proceeding to
judgment ; and from this it has been inferred that the Court
doubted whether they could inflict any punishment for an infraction
of the law of nations. But this was not the reason. The Court
never doubted that the law of nations formed a part of the law of
England, and that a violation of this general law could be punished
by them ; but no punishment less than death would have been
thought by the Czar an adequate reparation for the arrest of his
ambassador. This punishment they could not inflict, and such a
sentence as they could have given, he might have thought a fresh
insult. Another expedient was therefore fallen upon. However,
the princes of the world, at this day, are more enlightened, and do
not require impracticable nor unreasonable reparations for injuries
of this kind.
The second offence charged in the indictment, namely, the
assault and battery, needs no observations.
Upon the whole, the Court, after a most attentive considera-
tion of every circumstance in this case, do award, and direct me
to pronounce the following sentence :
That you pay a fine of one hundred French crowns to the
commonwealth ; that you be imprisoned until the fourth day of
July, 1786, which will make a little more than two years imprison-
ment in the whole ; that you then give good security to keep the
peace, and be of good behavior to all public ministers, secretaries
to embassies, and consuls, as well as to all the liege people of
Pennsylvania, for the space of seven years, by entering into a
recognizance, yourself in a thousand pounds, and two securities in
five hundred pounds each ; that you pay the costs of this
prosecution, and remain committed until this sentence be complied
with.
36 Cases on Criminal Law.
SECTION IV.
OFFENCES AGAINST RELIGION.
PEOPLE V. RUGGLES.
Supreme Court of New York, iSii.
8 Johnson, 290.
Kent, Ch. J.' delivered the opinion of the Court. The offence
charged is, that the defendant below did " wickedly, maliqiously,^
and blasphemously utter, in the presence and hearing of divers-
good iand Christian people, these false, feigned, scandalous, ma-
licious, wicked and blasphemous words, to wit : ' Jesus Christ
was a bastard, and his mother must be a whore ; ' " (and the
single question is, whether this be a public offence by the law of
the land). After conviction, we must intend that these words were
uttered in a wanton manner, and, as they evidently import, with a
wicked and malicious disposition, and not in a serious discussiprk
upon any controverted point in religion. The language was blas-
phemous not only in a popular, but in a legal sense; for blas-
phemy, according to the most precise definitions, consists in
inaliciously reviling God, or religion, arid this was reviling Christi-
anity through its author. Emlyn's Preface to the State Trials, p.
8. See,' also, Whitlock's Speech, State Trials, vol. 2. 273. The
jury have piassed upon the intent or quo animo, and if those words
spoken, in any case, will amount to a misdemeanor the indictment
is good.
Such words, uttered with siich a disposition, were an offence
at common law. In Taylor's case, i Vent. 293. 3 Keb. 607; Tre-
maine's Pleas of the Crown, 226. S. C. the defendant was convicted
upon information of speaking similar words, and the court of K. B.
said that Christianity was parcel of the law, and to cast contumelious
reproaches upon it, tended to weaken the foundation of moral ob-
ligation, and the efficacy of oaths. And in the case of Rex v,
1 Indictment and argument of counsel are omitted.
Cases on Criminal Law. 37
Woolston, Str. 834. Fitzg. 64, on a like conviction, the court
said they would not suffer it to be debated whether defaming Chris-
tianity in general was not an offence at common law, for that what-
ever strikes at the root of Christianity, tends manifestly to the
dissolution of civil government. But the court were careful to say,
that they did not intend to include disputes between learned men
upon particular controverted points. The same doctrine was laid
down in the late case of The King v. Williams, for the publication
of Paine's " Age of Reason," which was tried before Lord Ken-
yon, in July, 1 797. The authorities show that blasphemy against
God, and contumelious reproaches and profane ridicule of Christ or
the Holy Scriptures (which are equally treated as blasphemy), are
offences punishable at common law, whether uttered by words or
writings. Taylor's case, i Vent. 293; 4 Blacks. Com. 59; i Hawk.,
b. 1. c. 5; I East's P. C. 3; Tremaine's Entries, 225; Rex. v.
Doyley. The consequences may be less extensively pernicious in
the one case than in the other, but in both instances, the reviling is
an offence, because it tends to corrupt the morals of the people,
and to destroy good order. Such offences have always been con-
sidered independent of any religious establishment or the rights of
the church. They are treated as affecting the essential interests of
civil society.
And why should not the language contained in the indictment
be still an offence with us ? There is nothing in our manners or
institutions which has prevented the application or the necessity of
this part of the common law. We stand equally in need, now as
formerly, of all that moral discipline, and of those principles of
virtue, which help to bind society together. The people of this
State, in common with the people of this country, profess the
general doctrines of Christianity, as the rule of their faith and
practice ; and to scandalize the author of these doctrines is not
only, in a religious point of view, extremely impious, but, even in
respect to the obligations due to society, is a gross violation of
decency and good order. Nothing could be more offensive to the
virtuous part of the community, or more injurious to the tender
morals of the young, than to declare such profanity lawful. It
would go to confound all distinction between things .sacred and
profane ; for, to use the words of one of the greatest oracles of
human wisdom, " profane scoffing doth by little and little deface
38 Cases on Criminal Law.
the reverence for religion ;" and who adds, in another place, " two
principle causes have I ever known of atheism — curious contro-
versies and profane scoffing." Lord Bacon's Works, vol. 2. 291.
503. Things which corrupt moral sentiment, as obscene actions,
prints and writings, and even gross instances of seduction, have,
upon the same principle, been held indictable ; and shall we form
an exception in these particulars to the rest of the civihzed world?
No government among any of the polished nations of antiquity,
and none of the institutions of modern Europe (a single and mon-
itory case excepted) ever hazarded such a bold experiment upon
the solidity of the public morals, as to permit with impunity, and
under sanction of their tribunals, the general religion of the com-
munity to be openly insulted and defamed. The very idea of juris-
prudence with the ancient lawgivers and philosophers, embraced
the religion of the country. Jurisprudentia est divinarum atque hu-
manarum rerum notitia. Dig. b. I. 10. 2. Cic. De Legibus, b. 2,
passim.
The free, equal, and undisturbed enjoyment of religious
opinion, whatever it may be, and free and decent discussions on
any religious subject, is granted and secured ; but to revile, with
malicious and blasphemous contempt, the religion professed by
almost the whole community, is an abuse of that right. Nor are
we bound, by any expressions in the constitution, as some have
strangely supposed, either not to punish at all, or to punish indis-
criminately the like attacks upon the religion of Mahomet or of
the grand Lama ; and for this plain reason, that the case assumes
that we are a Christian people, and the morality of the country is
deeply ingrafted upon Christianity, and not upon the doctrines or
worship of those imposters. Besides, the offence is crimen malitice,
and the imputation of malice could not be inferred from any invec-
tives upon superstitions equally false and unknown. We are not to
be restrained from animadversion upon offences against public
decency, like those committed by Sir Charles Sedley, i Sid. 168,
or by one Rollo, Sayer, 158, merely because there may be savage
tribes, and perhaps semi-barbarous nations, whose sense of shame
would not be affected by what we should consider the most auda-
cious outrages upon decorum. It is sufficient that the common
law checks upon words and actions, dangerous to the public welfare,
apply to our case, and are suited to the condition of this and every
Cases on Criminal Law. 39
other people whose manners are refined, and whose morals have
been elevated and inspired with a more enlarged benevolence, by
means of the Christian religion.
Though the constitution has discarded religious establishments,
it does not forbid judicial cognizance of those offences against
religion and morality which have no reference to any such estab-
lishment, or to any particular form of government, but are punish-
able because they strike at the root of moral obligation, and weaken
the security of the social ties. The object of the 38th article of the
constitution, was, to " guard against spiritual oppression and intol-
erance," by declaring that " the free exercise and enjoyment of
religious profession and worship, without discrimination or prefer-
ence, should for ever thereafter be allowed within this State, to all
mankind." This declaration (noble and magnanimous as it is, when
duly understood), never meant to withdraw religion in general, and
with it the best sanctions of moral and social obligation from all
consideration and notice of the law. It will be fully satisfied by a
free and universal toleration, without any of the tests, disabilities,
or discriminations, incident to a religious establishment. To con-
strue it as breaking down the common law barriers against licen-
tious, wanton, and impious attacks upon Christianity itself, would
be an enormous perversion of its meaning. The proviso guards the
article from such dangerous latitude of construction, when it de-
clares, that " the liberty of conscience hereby granted, shall not be
so construed as to excuse acts of licentiousness, or justify practices
inconsistent with the peace and safety of this State." The preamble
and this proviso are a species of commentary upon the meaning of
the article, and they sufficiently show that the framers of the con-
stitution intended only to banish test oaths, disabilities and the bur-
dens, and sometimes the oppressions, of church establishments; and
to secure to the people of this State, freedom from coercion, and an
equality of right on the subject of religion. This was no doubt the con-
summation of their wishes. It was all that reasonable minds could re-
quire, and it had long been a favorite object, on both sides of the
Atlantic, with some of the most enlightened friends to the rights of
mankind, whose indignation had been roused by infringments of
the liberty of conscience, and whose zeal was inflamed in the pur-
suit of its enjoyment That this was the meaning of the constitu-
tion is further confirmed by a paragraph in a preceding article,
40 Cases on Criminal Law.
which specially provides that " su.ch parts of the common law as
might be construed to establish or maintain any particular denomi-
nation of Christians or their ministers," were thereby abrogated.
The legislative exposition of the constitution is conformable
to this view of it. Christianity, in its enlarged sense, as a religion
revealed and taught in the Bible, is not unknown to our law. The
statute for preventing immorality. Laws, vol. i. 224, R. S. 675, s,
69, et seq. consecrates the first day of the week, as holy time, and
considers the violation of it as immoral This was only the continua-
tion, in substance, of a law of the colony which declared, that the
profanation of the Lord's day was " the great scandal of the Chris-
tian faith." The act concerning oaths. Laws, vol. i. p. 405. 2
R. S. 407, s. 82, recognizes the common law mode of administer-
ing an oath, " by laying the hand on and kissing the gospels."
Surely, then, we are bound to conclude, that wicked and malicious
words, writings and actions which go to vilify those gospels, con-
tinue as at common law, to bean offence against the public peace
and safety. They are inconsistent with the reverence due to the
administration of an oath, and among their other evil consequences,
they tend to lessen in the public mind, its religious sanction.
The court are accordingly of opinion that the judgment below
must be affirmed.
Judgment affirmed}
1 Accord . Updegraph v. C, 11 S. and R., 394(1824). See also, dis-
tiirbing religious meeting, St. v. Jasper, 4 Dev., 323 (1833). — Ed.
Cases on Criminal Law. 41
SECTION V.
OFFENCES AGAINST PUBLIC PEACE.
REX V. SUMMERS.
King's Bench, 1701.
3 Salkeld, 194.
The defendant was indicted at the sessions, for writing a scan-
dalous letter to one Mellith concerning a young woman whom he
intended to marry. Upon not guilty pleaded, he was found guilty ;
and afterwards he brought a writ of error, and the error assigned
was, that this was a private letter, for which he was not pun-
ishable by way of indictment ; or, if an indictment would lie,
yet not before the justices of the peace at their sessions. Sect per
curiam, this is an offence, and indictable before the justices in ses-
.sions, because it tends to the breach of the peace.'
COMMONWEALTH v. HAINES.
Supreme Court of Pennsylvania, 1824.
4 Clark, 17.
This was a case removed by certiorari to the Supreme Court
from the Mayor's Court of Philadelphia, and tried before Gibson, J.,
at Nisi Prius, in September, 1824.
The first count of the indictment charged that the defendant,
devising and intending to raise and create riots, etc., with the usual
averments, " unlawfully, wickedly and maliciously incited, encour-
aged and endeavored to provoke and instigate divers good citizens
of the Commonwealth, whose names are to said inquest unknown,"
etc., "to assemble and gather together to disturb the peace of the
^Accord.; sending challenge, Rex w. Phillips, 6 East., 464 (1805). — Ed.
42 Cases on Criminal Law.
Commonwealth, and to injure and annoy said citizens, etc., and
that for that purpose, he, the said defendant, then and there erecting^
and fixing a certain figure, resembling a man, commonly called a
Paddy, as and for the effigy of St. Patrick, and by these means,
etc., did collect together a large number of citizens, who behaved
riotously for a long space of time," etc. The remaining counts
were for attempts to produce riot generally, without specifying the
means. It appeared from the evidence, that some time between
dusk and ii o'clock on the i6th of March, 1824, a stuffed Paddy,
with the accompaniment of a rum bottle and a string of potatoes,
was suspended to a tree near the junction of Second street and
Germantown road, in the district of Kensington, a neighborhood
inhabited principally by emigrants from Ireland. The figure
remained in this position until the next morning, when it was
removed to prevent a disturbance, which seemed likely to ensue.
The defendant, an inn-keeper residing in that district, was proved
by several witnesses to have been in his house during the whole of
the evening on which the Paddy was erected ; and a great deal of
conflicting evidence was produced, which made his agency in the
affair very questionable. The averment in the indictment that the
figure was intended as an effigy of St. Patrick, and was meant and
well calculated to excite the angry feelings of the immediate popu-
lation, was fully supported. It was proved also, beyond contest,
that the defendant was concerned in the exhibition on the 1 8th of
March, of a female figure, commonly called a Shelah, but with
several features, beside that of sex, distinguishing it from a Paddy.
Some evidence was offered to show, also, that while the exhibition
of a Paddy was resented as an insult upon the Catholic portion of
the Irish, a Shelah was often displayed as a retaliatory emblem,
and may have been so meant in the present case. A tumult ensued,
the insult being spiritedly resented, and the neighborhood was
thrown into confusion thereby for several succeeding weeks. The
defendant, it was conceded, was clearly connected with the Shelah,
though his instrumentality in the Paddy was controverted.
The jury having been addressed by Randall and Kittera for
the prosecution, and Biddle and D. P. Brown for the defence, were
charged substantially as follows, by
Gibson, J. The offence specified in the first count, is clearly
indictable at common law. No man has a right to trifle with the
Cases on Criminal Law. 43
feelings of any large class of men, so as to provoke them to a
breach of the peace. If it is done by libel, no one doubts it is a
misdemeanor ; if it is done by effigy is it less so ? Suppose the
defendant had published a picture of the same character, and with
the same tendency as the figure which is the subject of the present
offence, would it not be held a libel ? The gist of the offence is
its tendency to provoke a breach of the peace. It may be indis-
creet in the Irish residents of the district to take notice of acts of
the kind, but it is worse than indiscreet in others to provoke them to
do so. The facts are with you exclusively ; if you believe the
allegation of the indictment to be supported by the evidence, you
will be bound to convict.
The jury, after an absence of some hours, came into court
with the inquiry whether the allegation in the indictment that a
Paddy had been exhibited was supported by evidence of the exhi-
bition of a Shelah. The Court answered in effect, that, if the
characteristics and object of the Shelah were different from those
of the Paddy, the variance was fatal ; but that the question of the
identity or dissimilarity of the two was for the jury.
A verdict of acquittal was subsequently rendered.
Other acts indictable at common law as against the public peace, are :
Riot, which is defined to be, "A tumultuous disturbance of the peace,
by three persons or more assembling together of their own authority, with an
intent mutually to assist one another against any one who shall oppose them,
in the execution of some enterprise of a private nature, and afterwards
actually executing the same in a violent and turbulent manner, to the terror
of the people, whether the act intended were of itself lawful or unlawful. ' '
I Hawk., P. C. (Curw., ed.) 513. See Reg. v. Cunninghame, 16 Cox., C. C.
420, (1888).
Unlawful Assembly : ' • Any meeting whatsoever of great numbers of
people, with such circumstances of terror as cannot but endanger the public
peace, and raise fears and jealousies among the king's subjects." I Hawk.,
P. C.(Curw., ed.) c. 28, p. 516. See Reg. v. Vincent, 9 Car. and P., 91 (1839).
Affray ; "The fighting of two or more persons in some public place, to
the terror of his Majesty's subjects." IVBl. Com., 145. See St. z/. Sumner,
5 Strob. 53 (1850).
44 Cases on Criminal Law.
COMMONWEALTH v. TAYLOR.
Supreme Court of Pennsylvania, 1812.
5 Binney, 277.
The defendant was indicted in the Quarter Sessions of Frank-
lin county for "that he, on the 24th of August, 1809, about the
hour of ten of the clock in the night of the same day, with force
and arms, at Lurgan township, in the county aforesaid, the dwell-
ing house of James Strain there situate, unlawfully, maliciously
and secretly did break and enter, with intent to disturb the peace
of the Commonwealth ; and so being in the said dwelling house,
unlawfully, vehemently, and turbulently did make a great noise,
in disturbance of the peace of the Commonwealth, and greatly
misbehave himself in the said dwelling house ; and Elizabeth
Strain, the wife of the said James, greatly did frighten , and alarm,
by means of which said fright and alarm she, the said Elizabeth,
being then and there pregnant, did on the 7th day of September,
in the year aforesaid, at the county aforesaid, miscarry, and other
wrongs to the said Elizabeth then and there did, to the evil
example, &c.''
The jury having found the defendant guilty, the Quarter Ses-
sions arrested the judgment, upon the ground that the offence
charged was not indictable ; and the record was brought up to
this Court by writ of error;
Tilghman, C. J. It is contended on the part of James Taylor,
that the matter charged in the indictment is no more than a
private trespass, and not an offence subject to a criminal prosecu-
tion. On the other hand it has been urged for the Commonwealth
that the offence is indictable ; ist, as a forcible entry ; 2nd, as a
malicious mischief.
I. I incline to the opinion that the matter charged in the
indictment does not constitute a forcible entry, although no doubt
a forcible entry is indictable at common law. There must be
actual force to make an indictable offence. The bare allegation
of its being done with force and arms does not seem to be
sufficient, for every trespass is said to be with force and arms. In
the King v. Storr, 3 Burr, 1698, the indictment was for unlawfully
entering his yard and digging the ground and erecting a shed, and
Cases on Criminal Law. 45
unlawfully and with force and arms putting out and expelling one
Mr. Sweet, the owner, from the possession and keeping him out of
the possession. This indictment was quashed. The King v.
Blake and fifteen others, 3 Burr, 1 731, was an indictment for
breaking and entering with force and arms, a close (not a dwelling
house), and unlawfully and unjustly expelling the prosecutors, and
keeping them out of possession. This also was quashed, and the
rule laid down by all the court was, that there must be force or
violence shown upon the face of the indictment, as some riot or
unlawful assembly. It appears indeed, that in the King z/. Bathurst,
cited and remarked on by the judges in the King v. Storr, the
Court laid considerable stress on the circumstance of entering a
dwelling house. We have no report of that case, but Lord Mans-
field's observation on it 3 Burr, 1701 is, that it does not seem to
him to lay down any such rule as that force and arms alone
implies such force as will of itself support an indictment. "There,"
says he, "the fact itself naturally implied force; it was turning
and keeping the man out of his dwelling house, and done by three
people." In the case before us, there is the less reason to suppose
actual force, as the entry is charged to have been made secretly.
This might have been done through a door which was open, and
yet in point of law it was a breaking and entry with force and arms,
which is the allegation in evefy action of trespass.
2. But supposing the indictment not to be good for a forcible
entry, may it not be supported on other grounds ? In the case of
the Commonwealth v. Teischer, i Dall., 335, judgment was given
against the defendant for " maliciously, wilfully and wickedly kill-
ing a horse." These are the words of the indictment, and it seems
to have been conceded by Mr. Sergeant, the counsel for the
defendant, that if it had been laid to be done secretly, the indict-
ment would have been good. Here the entering of the house is laid
to be done " secretly, maliciously, and with an attempt to disturb
the peace of the Commonwealth." I do not find any precise line
by which indictments for malicious mischief are separated from
actions of trespass. But whether the malice, the mischief, or the
evil example is considered, the case before us seems full as strong as
Teischer's case. There is another principle, however, upon which
it appears to me that the indictment may be supported. It is not
necessary that there should be actual force or violence to constitute
46 Cases on Criminal Law.
an indictable offence. Acts injurious to private persons, which tend
to excite violent resentment, and thus produce fighting and dis-
turbance of the peace of society, are themselves indictable. To
send a challenge to fight a duel is indictable, because it
tends directly towards a breach of the peace. Libels fall within
the same reason. A libel even of a deceased person, is an
offence against the public, because it may stir up the passions of
the living and produce acts of revenge. Now, what could be
more likely to produce violent passion and a disturbance of the
peace of society, than the conduct of the defendant. He enters
secretly after night into a private dwelling house with an intent to dis-
turb the family, and after entering makes such a noise as to terrify the
mistress of the house to such a degree as to cause a miscarriage.
Was not this enough to produce some act of desperate violence on
the part of the master or servants of the family ? It is objected
that the kind of noise is not described. No matter ; it is said to
have been made vehemently and turbulently, and its effects on
the pregnant woman are described. In the case of the King v.
Hood (Sayers' Rep. in K. B., 161), the Court refused to quash an
indictment for disturbing a family by violently knocking at the
front door of the house for the space of two hours. It is impossible
to find precedents for all offences. The malicious ingenuity of
mankind is constantly producing new inventions in the art of dis-
turbing their neighbors. To this invention must be opposed general
principles calculated to meet and punish them. I am of opinion
that the conduct of the defendant falls within the range of estab-
lished principles, and that the judgment of the Court below should
be reversed. *
' Concurring opinions of Yeates and Brackenridge, JJ. are omitted.
Accord.; Henderson v. C, 8 Gratt, 708 (1852).
Cf. C. V. Edwards, i Ash., 46 (1823); C. v. Wing, 9 Pick., i (1829);
Kilpatrick v. P., 5 Denio, 277 (1848); St. v. Schlottman, 52 Mo., 164
(1873)-— Ed.
Cases on Criminal Law. 47
COMMONWEALTH v. CRAMER.
Court of Quarter Sessions of Dauphin, 1870.
2 Pearson (Pa.), 441.
By The Court. The defendant was charged under the
I S4th section of the Penal Code with having wilfully and maliciously-
maimed, disfigured and wounded a steer, the property of Jonas C.
Brinzer, and having been convicted at the last sessions, a motion
was made for a new trial on account of misdirection in the charge of
the Court, and also in arrest of judgment. There is no ground
whatever for arresting the judgment, as the indictment is good on
its face. The only question is, was it properly supported by the
evidence, and was the jury rightly instructed as to the law of the
case?
It was proved on the trial that at the time of the injury the
steer was trespassing on the enclosed grounds of the defendant ;
had repeatedly jumped into his cornfield, and was destroying his
corn; that he was verj' troublesome, addicted to jumping, and,
what might be called in common parlance "very breachy." The
defendant shot him many times with a gun heavily loaded with
shot, at one time wrapping up the charge and hitting him so
severely that he fell to his knees, but was able to run off and again
jump the fence, which was low and not in good order. The steer
was neither maimed nor disfigured, but was pretty severely
"wounded" by the shots, and greatly fell away in flesh. The
Court instructed the jury that the evidence did not bring the case
within the statute, but if he was wounded as charged in the indict-
ment, it was a crime at common law, although concluding contra
forma statuti. The only question of any difficulty was whether
the act must be done out of malice towards the owner, or malice
and passion against the animal. There was no pretence that there
was any malice towards the owner in this case, as the parties were
comparative strangers to each other and lived many miles apart.
The prosecutor's cattle were pasturing on an adjoining farm to the
defendant.
It is a little difficult to ascertain precisely what amounts to
malicious mischief by the common law. Blackstone, in his Com-
mentaries, Vol. 4, says: " The act must be done either out of a
48 Cases on Criminal Law.
spirit of wanton cruelty, or black and diabolical revenge." One
reason why we find so little on the subject in the English writers
on criminal jurisprudence tending to show what amounted to this
crime at common law, is that almost every possible injury to prop-
erty was punished by statutes, and the indictments have generally,
and perhaps always, for the last two hundred years, been preferred
under some one of the various acts of Parliament. It may be con-
ceded that in England it is settled that the offence must be committed
out of malice towards the owner of the injured property, unless, per-
haps, in cases of great and wanton cruelty towards domestic animals.
Even under their statutes it is held that there must be malice towards-
the owner. The worst acts of cruelty committed through passion
against the animal are not punished criminally. In this State, and
perhaps in many others, our laws have been construed differently.
When our various acts passed to protect property of any kind
speak of malicious and wilful injury thereto, we are justifiable in
saying that it applies to the forbidden act, whether done out of
malice toward the owner, or through a spirit of wanton mischief,
especially if accompanied with cruelty. Where malice is thus
mentioned, it does not mean hatred or ill-will, but imports an evil
disposition in general, a heart regardless of social duty. Our code
is full of provisions protecting inanimate objects, as well as animate,
and we hold that they are equally protected from wanton mischief,
or from injury or destruction out of malice towards the owner.
Wharton, our best writer on criminal law in this State, says, in
vol. 2, at p. 2002 : ", Malicious mischief in this country as a common
law offence has received a far more extended interpretation than
has been attached to it in England.", He defines it to be "any
malicious or mischievous injury, either to the rights of another or
those of the public, in general." In 3 Cushing, 558, it is said
"the jury must be satisfied that the injury was done either out of
a spirit of wanton cruelty or of wicked revenge." In Massachu-
setts the distinction seems, to be taken between injuries done to
animate and inanimate objects ; in the latter there must be malice
towards the owner, whilst in the former wanton cruelty is crimi-
nally punishable. It was held in that State to be indictable to
poison cattle, i Mass., R., 59.
The subject has undergone considerable examination in the
State of New York. Jn 5 Cowen, 218, "it is held tp be indict-
Cases on Criminal Law. 49'
able to maliciously, wickedly and wilfully kill a cow." The Court
speaks of the act being one of wanton cruelty, and that it cannot be
expected that a mind so depraved will tie restrained by a mere
liability to pay damages. The perpetrator may be insolvent, and
thus gratify his malice with impunity, if there is no redress other
than by civil action. The object is to protect the citizen in his right
by restraining and punishing the wrongdoer. Such acts discover a
degree of moral turpitude dangerous to society, and for its security
ought to. be punishable criminally. It is an evil example of the
most pernicious tendency, inasmuch as the act is an outrage upon
the principles and feelings of humanity.
In 19 Wend., 419, it was held to be indictable to wilfully,
wickedly and secretly break up a cutter, and 5 Cowen, 258, is cited
with approbation. The judge, after stating that in many courts it had
been held that such offences were not indictable, says he " is happy
to find that the weight of authority is the other way." "To say
that it was not so would be a sad exception to the general wisdom
of the common law." At an after time the courts of that State
decided in 5 Denio, 277, that it was not indictable at common law to
maliciously break the windows of another's dwelling. If done
secretly, it might be otherwise; at the same time the Court con-
siders that a criminal prosecution might be sustained for
maliciously kiUing or wounding domestic animals, as that shows
depravity of mind and cruelty of disposition, and the cases in i
Dallas, 335, and 5 Birtn. are spoken of with approbation, also that
already cited from 5 Coweri.
In I Aikin, Vt. R., 226, an indictment was sustained for cut-
ting, maiming and destroying colts. The judge says : " When the
most wanton cruelty to the beast is the grievance, we may pass by
the civil injury and treat the deed as a misdemeanor at common
law. With force and arms to injure the property of another is a
civil injury, for which the owner of the property may have his
action of trespass. But the wounding and torturing a living animal,
not only with force and arms, but with all the malicious and wicked
motives and intentions set forth in this indictment, is a misdemeanor
to be prosecuted by the judges." This case appears afterwards to
have been disregarded and overruled in that State, but in our
opinion is good law and sound morals.
In Pennsylvania we have perhaps gone further than in any
50 Cases on Criminal Law.
other State in punishing malicious mischief. As early as 1788, in
Teischer's case, i Dal., 335, it was held indictable to mahciously,
wilfully and wickedly kill a horse, and McKean, Ch. J., says,
whatever amounts to a public wrong may be made the subject of
an indictment. The poisoning of chickens, cheating with false
dice, fraudulently tearing a promissory note, and many other
offences of a similar description have heretofore been indicted.
Breaking windows by throwing stones at them, embezzling public
money, so for maliciously killing a dog, for writing threatening
letters to obtain money, 2 Dal., 297 ; girdling a tree growing on
pubhc ground, 2 Brown, 249 ; so to enter the house of another,
make a great noise, and disturb and alarm the family, 5 Binn. ; to
be guilty of wanton cruelty to animals in general, 2 W. C. C. R.,
259 ; to put cQwitch on a towel to injure a person about to use it,
1st W. C. C. R., 490 ; to cut off the hair from the mane or tail of
a horse, 2 Humphreys, 39 ; to discharge a gun with intent to dis-
turb a sick person, 9 Pick., i ; so to destroy a line tree or other
landmark ; to set fire to a number of barrels of tar belonging to
another ; so to cast the carcass of a dead animal into a well in
daily use, 8 New Hamp., 208. Most of these cases are cited in
2 Wharton's C. L., p. 2003. We have known convictions to be
had in different Courts of Quarter Sessions in this State for various
other offences, which in England would only be punished by civil
suit, except when a criminal remedy is given by statute, as cutting
off the young trees growing in a nursery ; girdling fruit trees ;
throwing a dead porcupine into a well ; breaking up the kettles in
a sugar camp, and splitting the sugar troughs ; throwing down a
man's fences in the night and turning a drove of cattle into
his wheat ; placing gunpowder in a log of stove wood, by which
the stove was blown up ; plastering a number of doors with tar
through mere wanton mischief ; cutting to pieces and destroying
the melons growing in a large patch ; breaking to pieces a number
of grindstones standing at a store door for sale,, through mere
wantonness, and not out of malice towards the owner ; cutting in
pieces the curtains and cushions of a carriage ; burning a pile of
rails, also piles of cordwood intended for coaling ; setting fire to a
haystack ; cutting down a mill dam ; opening the sluice in a mill-
race for wanton mischief, and turning the water over the owner's
meadow, by which the partially made hay was destroyed ; tying
Cases on Criminal Law. 51
shingles to a horse's tail, by which he was greatly frightened and
ran until so injured as to be useless to the owner, though in the
case the horse was trespassng.
Judge Lewis, in his work on criminal law, p. 305, says :
" Whatever amounts to a public wrong may be made the subject of
indictment ; " and in addition to many instances already stated,
gives that of furiously driving through the streets of a crowded
city ; so contemptuously tearing down and refusing to replace
an advertisement of a public subject ; so maliciously cutting down
timber trees with intent to injure the owner is indictable at common
law, independent of the statute ; breaking down and defacing tomb-
stones in a graveyard ; also covering a dog with spirits of turpen-
tine and setting the animal on fire, through a spirit of wanton
mischief. Many other cases of conviction of like offences may be
cited. We may therefore fairly assume that, although acts'of this
character described, when not done out of malice towards the
owner of the property, are not the object of a criminal prosecution
in England and many of our sister States, are by almost universal
understanding and consent made so in Pennsylvania. It has
become part of our common law, and is highly conducive to public
morals and beneficial to society. The acts are evidence of wanton
cruelty, a spirit of mischief, or of black revenge, according to their
nature and character, are indications of the mala mens and evil
disposition in general, and are punishable by the criminal law.
In the case before us the owner of the cornfield could have
had ample redress for the injury done by the steer had he pro-
ceeded under the law relating to estrays or by an action against
the owner. Instead of pursuing a legal remedy he resorted to
acts of barbarity, which are themselves evidence of malice. Although
we may, in pronouncing sentence, take into consideration the
provocation to anger by the trespasses of the animal, yet we can-
not avoid imposing some punishment on the defendant for his
violation of the criminal law.
It is very seriously contended that this code was intended to
embrace all criminal offences, and thus abrogate the common law,
We should be sorry so to decide, as thereby a vast many crimes
most injurious to society would go unpunished. This code does
not embrace one-half of the crimes known to the law. Besides the
statute is inflexible and unbending, whilst the common law adapts
52 Cases on Criminal Law.
itself to the new devices of mankind to injure society, and punishes--
them as they arise. It is further insisted that the 48th and 63d
sections were intended to cover every case of malicious injury,
and that this case does come within the 48th section, thoughi
not properly described as being done "wantonly and cruelly."
We are of opinion that section was intended to cover a different-
class of cases, and the 163rd section as reported would have
embraced this ; but its symmetry was marred by the legislature in
leaving out the word " wounding," as inserted by the commis-
sioners. That leaves the common law in force in cases of wounding
as it stood prior to the formation of the code. Concluding contra
forma statuti is unimportant, as it has been settled for more than
half a century that such words are surplusage merely where the
offence existed at common law. The motion for a new trial is
overruled.
SECTION VI.
OFFENCES AGAINST PUBLIC HEALTH.
REX V. TAYLOR,
King's Bench, 1742.
2 strange, 1 167.
The Court granted an information against him as for a nui-
sance, on affidavits of his keeping great quantities of gunpowder,
to the endangering the church and houses where he lived.^
1 Accord: Reg. z/. Lister, Dears. & B., 209(1856). [Cf. P. v. Sands,
I Johns, 78 (1806.)]. Obstructing navigable river, St. v. Thompson, 2 Strob.,
12 (1847); obstructing highway, Reading v.C, \\ Pa„ 196 (1849); main-
taining slaughter house near dwelling, Moses v. St 58 Ind., 185 (1877). Ed.
Cases on Criminal Law. 53
REX V. VANTANDILLO.
King's Bench, 181 5.
4 Maule &^ Selwyn, 73.
The defendant was indicted for carrying her child while
anfected with the small pox along a public highway.
Owen moved in arrest of judgment, that this was an indictment
of the first impression. He observed, that the defendant was not
indicted for inoculating, or causing the child to be inoculated with
an infectious disease ; for it is not stated how the child came by it.
.And it is consistent with this indictment that the child might have
^caught the disease; and supposing it had, might not the mother carry
lit through the street in order to procure medical advice without
Jjeing subject to be indicted for it ? Therefore the indictment ought
to have shown that the act was unlawful ; and ought also to have
-alleged that there was some sore upon the child at the time when
it was so carried, by analogy to the writ " de leproso amovendo,"
which, it seems, lay only for those who appeared to the sight of
all men by their voice and sores to be lepers, and not for those
infected with the disease, but not outwardly in their bodies. See
Fitz., N. B. 534. And if the merely alleging that the disorder is
infectious and dangerous to the subjects, be sufficient, there is a
multitude of diseases of which the same may be predicated, and
consequently the patient during the continuance of any such disease
must never go abroad at all ; so difficult will it be to draw the line.
The only offences against the public health of which Hawkins speaks,
•are spreading the plague and neglecting quarantine. Hawk., P. C.
-c. 52, 53 ; and Lord Hardwicke, it appears, thought the building of
^ house for the reception of patients inoculated with the small pox
was not a public nuisance, and mentioned that upon an indictment
of that kind there had lately been an acquittal. And he added, that
the fears of mankind, though they may be reasonable, will not create
-a nuisance, 3 Atk., 750.^
Le Blanc J. in passing sentence observed that although the
Court had not found upon its records any prosecution for this
iThe indictment, argument of counsel for the crown, and concurring
.opinion of EUenborough, C. J. , are omitted.
54- Cases on Criminal Law.
specific offence, yet there could be no doubt in point of law that if
a person unlawfully, injuriously, and with full knowledge of the
fact, exposes in a public highway a person infected with a con-
tagious disorder, it is a common nuisance to all the subjects, and
indictable as such. However, the Court was not disposed upon
the present occasion to impute to the defendant an intention of
being the cause of the consequences which had followed. Neither
did they pronounce that every person who inoculated forthis disease
was guilty of an offence, provided it was done in a proper manner,
and the patient was kept from the society of others so as not to
endanger a communication of the disease. In such a case the law
did not pronounce it to be an offence. But no person having a dis-
order of this description upon him ought to be publicly exposed to
the endangering the health and lives of the rest of the subjects.
The defendant was sentenced to imprisonment in the custody
of the marshal for three ca:lendar months.^
COMMONWEALTH v. CASSIDY.
Quarter Sessions of Philadelphia, 1865.
6 Philadelphia, 82.
Motion to quash the indictment.
Allison, J. This motion is based on several grounds — first,
that the facts laid in the bill do not constitute an indictable
offence. In this we do not agree with the defendant. To do any
act which is calculated to spread terror and alarm through the
community, unless such act is right and proper in itself consid-
ered, or becomes necessary under the special circumstances sur-
rounding the commission of that which is complained of as con-
stituting an offence, renders the person so offending liable to-
indictment at common law.
For illustration, to circulate a report of an invasion, or the
breaking out of an infectious or contagious disease, if the report
be false, would be indictable, because such reports are calculated
^Accord: Selling unwholesome food, Rex v. Dixon, 3 M & S., 11 (1814);.
throwing carcass into a well, St. v. Buckman, 8 N. H,, 203 (1836); bringing
horse infected with glanders into a public place, Reg. v. Henson, i Dears.,
24 (1852); selling unwholesome water, Stein v. St., 37 Ala., 123 (1861). — Ed.
Cases on Criminal Law. 55
to excite unnecessary fear and terror in the minds of the people ;
whilst if the facts corresponded with the report, no indictment
would lie, because it would under ordinary circumstances be
eminently proper that such information should be given to the
public.
The general principle is that whatever is injurious to a large
class of the community is a nuisance at common law. Lansing v.
Smith, case 146. The carrying on of a trade, which is in itself
lawful, if it is injurious to the comfort of the community gen-
erally, or the immediate neighborhood, constitutes a nuisance.
People V. Cunningham, i Denio, 524. Upon this principle, indict-
ments have frequently been sustained in this court for maintaining
a bone boiling or lampblack establishment. So also, a swineyard
in a city or thickly populated neighborhood is a nuisance. Com-
monwealth V. Vansyckle, Brightly, R., 69.
These and kindred cases rest on the ground of their causing
discomfort merely to the public. If indictments will lie for cause
like to those named, it does not require authority for the doctrine
that whatever injuriously affects the health or the morals of a large
class of the community, is indictable as a common nuisance — such
as the letting off of fireworks in a public street, or the keeping of
a disorderly house.
This indictment charges the unlawful circulation of a false
report by handbills posted on the corners of public streets, and
other public places in the city, calling on the citizens to look out
for a child stealer, describing her as a woman about twenty-four
years of age, etc. The hope is suggested that she may be dis-
covered and brought before the public, where she may be observed
by both heads of families and their children, etc.
That this publication, given to the public in the manner above
stated, constitutes, in whatever light it may be viewed, a common
nuisance, cannot, we think, be well questioned ; that it is injurious
to both the comfort and health of a large number of persons in
the community in which the report has been put in circulation, is
self-evident, because its tendency is to fill the mind with anxiety,
fear and alarm, to the absolute destruction of the comfort and
happiness of many, and by this means is to a greater or less
extent, injurious to the health of persons brought under such
influences.
56 Cases on Criminal Law.
Mental anxiety, and an imagination excited by terror, are
fruitful sources of bodily disease and loss of life, and upon none of
the instincts and susceptibilities of our nature do these influences
tell with greater power than when brought to bear upon the
anxiety of parents for the safety of their offsprings.
The motion to quash is overruled}
SECTION VII.
OFFENCES AGAINST TRADE.
RESPUBLICA V. POWELL.
Supreme Court of Pennsylvania, 1780.
I Dallas, 47.
This was an indictment against the defendant, a baker em-
ployed by the army of the United States, for a cheat, in baking 219
barrels of bread; and marking them as weighing eighty-eight pounds
each, whereas they only severally weighed sixty-eight pounds.
The indictment being originally found at the City Court, in October
Sessions, 1779, was removed by certiorari into this Court.
And now Lewis, for the defendant, contended, that false
tokens are only indictable by the St. of 33 Hen., S, c. i, which has
no operation in Pennsylvania, and he cited 3 Burr., 1697; i Burn.,
291 ; 2 Sess. Ca., 2.
The Attorney General {Sergeant) insisted that the defendant's
office was a public trust; and cited 2 Burr., 1125; i Hawk., 187.
The Court said, that this was clearly an injury to the public ;
and the fraud the more easily to be perpetrated, since it was the
customa to take the barrels of bread at the marked weight, without
weighing them again. The public, indeed, could not by common
prudence prevent the fraud, as the defendant was himself the officer
of the public pro hac vice. They were therefore of opinion, that
the .©ffeince was indictable.
■' Part of this case relating to another point is omitted.
Cases on Criminal Law. 57
MIDDLETON v. STATE.
Court OF Appeals OF South Carolina, 1838.
Dudley, 275.
O'Neall, J. delivered the opinion of the Court.*
The indictment charges the defendant in three counts, as
follows; to wit : ist. That she did overreach. 2nd. That she did
cheat. 3d. That she did defraud one Alexander L. Gregg of
sundry articles of property, by passing to him a promissory note
-on one L. G. Smith and John Foxworth for ten dollars, pretending
ithat it was of that value, and that the makers were in law liable to
jpay, and would pay the same, when she in fact knew that they were
mot liable to pay, and would not pay the same. This is the sub-
stance of the charges.
The first inquiry arises, is any offence at common law charged?
T think it is very clear there is not. It is a mere civil injury, for
which the party injured might have his remedy by action of deceit.
It is a mere false representation of a thing to be of value, which
4he defendant knew to be valueless. There is in this no offence
against the public. It is in its consequences and effects confined to
the parties to the transaction, and thus at once shows that no prose-
•cution at common law can be sustained. The definition of a cheat
-at common law, given by Russell, in his 2nd vol., 139 — the fraud-
ulent obtaining of property of another, by any deceitful and illegal
practice or token (short of felony) which affects or may affect the
public, seems to give, in general terms, the most proper notion of
the offence, which I have been able to meet with. It has the sup-
port of the case of the King v. Wheatly, 2 Burr., 1125, in which
the defendant was indicted for selling sixteen gallons of amber
when it had been represented by him at eighteen gallons, and sold
accordingly, the defendant well knowing that the true quantity
was sixteen gallons ; it was held that this was no offence, and that
the judgment must be arrested. In that case, Lord Mansfield
stated the rule to be, that " The offence that is indictable must be
'Argument of counsel and part of the opinion construing the St 1791
■omitted.
58 Cases on Criminal Law.
such an one as affects the public — as if a man uses false weights
and measures, and sells by them to all or many of his customers,
or uses them in the general course of his dealings ; so if a man de-
frauds another under false tokens. For these are deceptions that
common care and prudence cannot guard against.
Speaking of the case then before the Court, and applying to it
the test of the rules which he had stated, he said, " it is a mere
private deception." The definition given in Russell, and the case
of King V. Wheatly, sustain fully the remarks which I made in the
outset of my opinion, and show that the indictment cannot be sus-
tained at common law. The Statute 33 Henry, 8, c. i, P. L., 55,
'<■ has been supposed in the argument, may sustain the conviction ;
it is, therefore, now necessary to look to it. The preamble to the
statute states the mischief to be, that many light and evil-disposed
persons, " had falsely and deceitfully contrived, devised and imag-
ined privy tokens and counterfeit letters in other men's names,
unto divers persons, their specified friends and acquaintances, for
the obtaining of money, goods, &c.," it is therefore enacted, that
" if any person or persons falsely, and deceitfully, obtain or get into
his or their hands or possession, any money, goods, chattels, jewels,
or other things, of any other person or persons, by color and means
of any such false token or counterfeit letter, &c.," he should on con-
viction be punished by imprisonment, pillory, or other corporal
pain (except pains of death) at the discretion of the Court.
Under this statute, as well as at common law, the obtaining^
money or goods by false token is punished.
It is, therefore, now necessary, in this connection, to inquire
what is a false token. It is somewhat difficult to define with pre-
cision, or rather to describe, a false token in all cases. Taking the
preamble of the statute as our guide, we would say it must be
something false and purporting to come from one not the bearer,,
and having in itself some private mark or sign, calculated to induce
the belief that it is real, and thus to cause the person to whom it
is delivered to part with his money or goods to the bearer or person
delivering it. On looking into 2 Russell, 1384, 1 find the definition
which I have given, is substantially that which he approves. This
would be enough for this part of the case, for it is manifest that
the note set out in the indictment could not be a privy false token,
according to the definition or description which has been given.
Cases on Criminal Law. 59
But it may be well here to notice what is meant by a false token
at common law ; for it will, perhaps, aid us in the view which we
may have to take of this case under the Act of '91. It seems to me
that it is anything which has the semblance of public authority, as
false weights, measures, seals and marks of produce and manufac-
tures, false dice, marked cards, and things of a similar kind, false
and deceptive, used in unlawful games ; 2 Russ. on Crimes, 1368.
It is true, in looking into the books, we find many cases of indict-
ment, in which fraud is an essential requisite, as in cases of common
cheat, forgery and conspiracy ; and some confusion has arisen from
such cases being often spoken of under the general head of cheats
at common law, and, therefore, mingled with the offence of cheat-
ing or swindling by false tokens. But each of them constitutes an
independent and distinct offence.
The motion in arrest of judgment is granted. ^
SECTION VIII.
OFFENCES AGAINST PUBLIC DECENCY.
BELL V. STATE.
Supreme Court of Tennessee, 1851.
I Swan, 42.
McKiNNEY, J. delivered the opinion of the Court.
The plaintiff in error was indicted and convicted in the Circuit
Court of Blount, for the utterance of certain grossly obscene words
in public, and in the hearing of divers persons, in the town of
Louisville in said county. The different words alleged to have
been spoken, are set forth in three different counts. This was nec-
essary to the validity of the indictment, but we omit to repeat them
here ; because of their extremely vulgar and offensive character.
It is sufficient to state, that they relate to acts of criminal inter-
1 Accord: See also C. v. Warren,^ Mass. 72 (1809); Rex v. Haynes, 4
M. & a, 214 (181 5) ; C. V. Gallagher, 14 Pa. L J., 58 (1844).— Ed.
6o Cases on Criminal Law.
course alleged by the defendant to have taken place between him
and the daughters of Abraham Hartsell, and to a loathsome
disease, said by the defendant to have been contracted by him from
the wife of Hiram Hartsell.
Two questions are presented for our determination : First,
is the utterance of obscene words, in public, an indictable offence?
And if so, secondly, are the words proved sufficient to support the
charges in the indictment ?
Upon the first point, the argument for the plaintiff in error
rests upon the narrow and unsubstantial ground, that no precedent,
or adjudication, has been found in support of such an indictment.
Admitting this to be true, for the present, what does it establish ?
If the case stated in the indictment falls within the operation
of clear, well defined, and well established principles of law, is it to
be urged against the maintenance of this prosecution, that no
similar case has heretofore occurred calling for the Hke application
of such principles ? Surely not, at this day. Are not innumerable
instances to be found in the modern Reports, both of England and
America, in which the liberal, enlightened, and expansive principles
of the common law have been adapted and applied to new cases,
for which no precedents were to be found, so as to meet the ever
varying condition and emergencies of society? And this must
continue to be so, unless a stop be put to all further progress of
society ; and unless a stop be also put to the further workings of
depraved human nature, in seeking out new inventions to evade
the law.
What then are the well established principles of the common
law, applicable to the present case ?
The distinguished commentator on the laws of England informs
us, that upon the foundations of the law of nature and the law of
revelation, all human laws depend, i Bl. Com., 42. The municipal
law looks to something more than merely the protection of the
lives, the liberty, and the property of the people. Regarding Chris-
tianity as part of the law of the land, it respects and protects its
institutions ; and assumes likewise to regulate the public morals
and decency of the community. The same enlightened author,
I Vol. Com. 124, distinguishes between the absolute and relative
duties of individuals, as members of society. He shows very clearly
that, while human laws cannot be expected to enforce the former.
Cases on Criminal Law. 6i
their proper concern is with social and relative duties. Municipal
law being intended only to regulate the conduct of men, considered
under various relations, as members of civil society ; hence he lays
it down, that however abandoned in his principles, or vicious in his
practice, a man may be, provided he keeps his wickedness to him-
self, and does not offend against the rules of public decency, he is
out of the reach of human laws. But, says the learned writer, if
he make his vices public, though they be such as seem principally
to affect himself — as drunkenness or the like — they then become,
by the bad example they set, of pernicious effect to society ; and,
therefore, it is then the business of human laws to correct them.
See also 4 Bl. Com., 41, 42.
It is certainly true, that in England many offences against
good morals and public decency, if committed in private, belong
properly and exclusively to the ecclesiastical courts. But it is
equally true, that whenever they become public, so as thereby to
become of pernicious example, or offensive to pubhc morals and
decency, they fall within the proper jurisdiction of the temporal
courts.
In the case of The King v. Delard, et al., 3 Burr. R., 1438,
which was an information for conspiracy, for putting a young girl
into the hands of a man of rank and fortune, for the purpose of
prostitution — Lord Mansfield laid it down, that, except as to
those cases appropriated to the ecclesiastical court, the court of
King's Bench in the custos morum, or guardian of the morals of the
people, and has the superintendency of offences contra bonos mores;
and upon this ground, he says, both Sedley and Curl, who had
been guilty of offences against good manners, were prosecuted in
that court.
In I Russell on Crimes, 270, at top, it is said that, " In
general, all open lewdness, grossly scandalous, is punishable by
indictment at the common law ; " and, says the author, " it appears
to be an established principle, that whatever openly outrages
decency, and is injurious to public morals, is a misdemeanor." So
Blackstone lays it down, 4 Com., 64, that any grossly scandalous
and public indecency, is indictable, and punishable in the temporal
courts by fine and imprisonment.
These principles have been fully recognized by this court. In
the case of Grisham and Ligon v. The State, 2 Yerger, that
62 Cases on Criminal Law.
thorough common lawyer, the late Judge Whyte, declared that
"The common law is the guardian of the morals of the people,
and their protection against offences notoriously against public
decency and good morals." And he adds, in another part of the
same opinion, " we have the express authority of the common law,
as declared by the Judges in the courts of justice, that all offences
against good morals are cognizable and punishable in the temporal
courts, that are not particularly assigned to the spiritual court."
The books of Reports, both of England and this country,
abound with cases where, upon these principles of the common
law, convictions have been enforced for various offences against
public morality and decency, without the aid of any statutory
enactment. And surely it can be no reason for the relaxation of
these salutary principles, but rather the contrary, that in this coun-
try we have no "spiritual court," to lend its aid in the suppression
of the numerous offences faUing within the class now under consid-
eration ; and that such of them as cannot be reached in the mode
pursued in the case before us, must "go unwhipt of justice."
It would be tedious to enumerate the cases in which offences
have been held indictable as contra bonos mores — a few will suffice
for the present purpose. Public drunkenness, 4 Bl. Com., 41.
All indecent exposure of one's person to the public view, id. 65,
n. 25. In the case of The King v. Crunden, 2 Campb., 89, i
Russ. on Crimes, 302, it was held an indictable offence to bathe in
the sea near inhabited houses, from which the person might be
seen ; although the houses had been recently erected, and previ-
ously thereto it had been used for persons in great numbers,to bathe
at such place. And it was so held, for the reason, " that what-
ever place becomes the habitation of civilized men, there the laws
of decency must be enforced."
So it has been held by this Court, that if the master of a slave
in his employ, permit such slave to pass about, in view of the
public, so meanly clad as not to protect the person of such slave
from indecent exposure, the master is indictable for lewdness, or
scandalous public indecency : 3 Humph. R., 203. And it may be
laid down, in general terms, that all such acts and conduct as are
of a nature to corrupt the public morals, or to outrage the sense of
public decency, are indictable, whether committed by words or
acts.
Cases on Criminal Law. 63
These adjudications, without citing others, we think furnish
analogies sufficiently strong to sustain the present prosecution. Are
the outrageously vulgar and obscene words found in this record,
if uttered in the ear of the public, less likely to shock any one's
sense of decency, and to corrupt the morals of society — not to
speak of their inevitable tendency to provoke violence and blood-
shed — than the offences charged in the several adjudicated cases
above cited? It does not so appear to us. But, were there no
analogy to be drawn from any decided case, we hold, that, upon
the broad principles of the common law which we have stated, this
prosecution is most amply sustained. Thus fortified by sound prin-
ciples — principles which lie at the foundation of every well regu-
lated community — (and resting on a basis so immutable) we are
the more indifferent as to precedents exactly in point.*
Let the judgment be affirmed.^
STATE V. WILLIAMS.
Superior Court OF Tennessee, 1808.
2 Overton, 1 08.
Indictment in the county court for eavesdropping ; appeal to
this court, and the only question was whether such a prosecution
can be maintained.
It was insisted for the defendant, ist, that there was no statute
of the State upon the subject. 2d, That the act which adopted
the laws of England confined such adoption to such as are con-
sistent with our mode of living. 1715, c. 31, s. 5. No precedent
can be found of such an indictment, which furnishes a strong infer-
ence that such a prosecution was not conformable to the principles
of our government, or modes of living.
By the Court — ^Powell J. and Overton J. absent, Campbell J.
'Part of the case is omitted.
^Accord: St. ^'. Appling, 25 Mo., 315 (1857); exhibition of indecent picture,
C. V. Sharpless, 2 S. & R., 91 (18 15); indecent exposure of person, Britain v.
St., 3 Humph., 203 (1842); C. V. Spratt, 14 Phila., 365 (1880); cf. Reg. v.
Watson, 2 Cox, C.C, 376 (1847); night walking, St. v. Dowers, 45 N. H.,543
(1864); keeping common gaming house, P. v. Jackson, 3 Denio, loi (1846);
exhuming body for dissection. Rex v. Lynn, 2 T.R., 733 (1788); sodomy, C.
V. Thomas, i Va. Cas., 307 (18 12); keeping, or leasing house for immoral
purposes, P. v. Erwin, 4 Denio, 129 (1847). — Ed.
64 Cases on Criminal Law.
Agreeably to the common law, such an indictment well lies, and
nothing can be seen in this part of it, which is inconsistent with,
our situation, or in fact the situation of any society whatever.*
ANDERSON v. COMMONWEALTH, 1826.
General Court of Virginia, 1826.
5 Randolph, 627.
The indictment against the plaintiff in error, contained two
counts, the first of which charged that he, being a married man,
on the 22d November, 1825, in the said county of Chesterfield, one
Elizabeth F. Hargrove a maiden, and unmarried, and under the
age of twenty-one years, that is to say, of the age of sixteen years,
two months, and nineteen days, having no father living, and being
then and there under the care and custody of Elizabeth Hargrove,
a widow, her mother, did entice, inveigle, take and carry away from
the care and custody of her said mother, for the purpose of pros-
tituting and carnally knowing her the said Elizabeth F. against the
peace and dignity of the Commonwealth. The second count in
like manner charges him with the enticing, inveigling, taking and
carrying away the said infant over the age of sixteen years, and
moreover charges that he did, on a subsequent day, deflour, car-
nally know, and prostitute her the said Elizabeth F. Hargrove,
against the peace and dignity of the Commonwealth.
Dade, J. delivered the opinion of the Court.
The question is, whether the offence of which the plaintiff has
been convicted, and had judgment, is a misdemeanor, punishable
by indictment at the common law.
The class of misdemeanors within which it is insisted this
offence is comprehended, is that of offences contra bonos mores, over
which the Court of King's Bench in England, and the Superior
Courts of Law of this Commonwealth, have always claimed tO'
have jurisdiction. It is admitted, that before the statute oi circum-
specte agatis, 13 Edward i, the Court of King's Bench did on this
principle punish the offence of incontinency, and that by that
statute the jurisdiction was transferred to the ecclesiastical courts
^Accord: Common scold, James v. C, 12 SL & R., 220 (1825); C. v.
Lovett, 6 Pa. L. J., 226 (1831); St. v. Pennington, 3 Head, 299 (1859). — Ed.
Cases on Criminal Law. 65
It may be wtU doubted whether the King's Bench before the
statute, or the Courts Christian since, looked beyond the simple
fact of incontinence, as that offence is at present contemplated
and punished by our own Acts of Assembly. In other words,
whether they looked beyond the mere offence of incontinence, as
consisting in the single act of cohabitation between persons of dif-
ferent sexes, without the rites of marriage, not varied by any fraud,
deception, or inveiglement which may have been practised by the
man. But after the statute of circumspecte agaiis, the Court of
King's Bench did not exercise jurisdiction in punishing the mere
act of incontinence. It, however, retained its general power of
punishing offences contra bonos mores, and it is presumed might
have punished an offence of incontinence combined with circum-
stances, which, beyond the mere criminality of the simple fact, were
calculated to make it injurious to society ; as, in case of inconti-
nence in a street or highway. But, in such cases the jurisdiction
would not spring from the criminal character of the simple fact,
but from its publicity ; as, there are many cases where an act,
which is not criminal in private, becomes penal by the publicity
which attends its perpetration. The act of Sir Charles Sedley, in
running naked through the streets, derived its whole criminality
from its publicity. It is not, therefore, in this case allowable to con-
nect the criminality of the mere act of incontinence, which as such,
is punishable in a certain mode prescribed by the statute, with the
particular circumstances of fraud and deception, and the special
injury to the female, so as to make the supposed common law
offence, (as the Courts might entertain it in England, since the
statute oi circumspecte agatis), derive support, or even acquire being
from the statutory offence. If the statutory misdemeanor of simple
incontinence is to be punished, it must be according to the statute.
If there be other circumstances in the case which entitle the Com-
mon Law Courts to jurisdiction, those circumstances must of them-
selves constitute a misdemeanor. By these principles, the only two
reported cases in the English books are to be tested. The case
of The King v. Lord Grey and others, 9 State Trials (Cobbet's
edition), p. 127, was that of an information, alleging a conspiracy
to take away, and debauch a maiden over the age of sixteen, and
under twenty-one, and an accomplishment of the act by those
means. This conspiracy is emphatically charged in the informa-
66 Cases on Criminal Law.
tion, and as it was to do a wrongful act, for which certainly, if done,
an action lay to the father of the maid, the conspiracy, if proved,
clearly amounted to a common law misdemeanor. So, in the case
of Sir Francis Blake Delaval and others, 3 Burr., 1432, which was
" a motion for an information against the defendants for a conspir-
acy to put a young girl into the hands of a gentleman of rank and
fortune, for the purpose of prostitution," although Lord Mansfield,
in allowing the motion, intimates an opinion that the Court of
King's Bench might have jurisdiction of the case, as one contra
bonos mores, yet he decides it on the ground that there was in that
case, " a conspiracy, and confederacy ;" which, says he, "are clearly
and indisputably within the proper jurisdiction of this Court."
Without doubt in these cases, the Court having jurisdiction of them,
on undeniable common law principles, the punishment in case of
conviction, might well be aggravated by the baseness, perfidy, or
malignity, which was the motive and end of the conspiracy. In
like manner, as in trespass, circumstances may aggravate the dam-
ages, which would not of themselves alone support the action.
But clearly, neither of these cases does maintain the position, that
as a common law misdemeanor, an indictment or information, will
lie, either for simple incontinence, or for incontinence produced by
means of deception, inveiglement, or enticement, in other words,
by seduction.
It is too late now to assume jurisdiction over a new class of
cases, under the idea of their being contra bonos mores. We must
consider the practice of the English Courts, from which we derive
the principle, as having settled in the course of many centuries, the
true limits and proper subjects of this principle. If we are to dis-
regard these landmarks, and take up any case which may arise
under this principle, as res Integra, then might it be extended to
cases which none has yet thought of as penal. A case of slander
may display as much baseness and malignity of purpose, as much
falsehood in its perpetration, as ruinous effects in its conse-
quences, and as pernicious an example in its dissemination, as
this case of seduction. And yet none would think of prosecut-
ing it criminally. It is true, that if something peculiar in our sit-
uation had given rise to a class of cases contra bonos mores, as in
regard to our slaves, which could not have existed in England, we
might be justified in applying the rule in the absence of all prece-
Cases on Criminal Law. d^,
dent. But, in relation to seduction, no such supposition can be
made, as we l^r Alderson, B., Reg. v.
Brown, i C. & M., 314, by the same learned Baron, and by Bram-
well, B., in Reg. v. Young, 10 Cox C. C, 371.
The cases in which it has been held that persons may lawfully
engage in friendly encounters not calculated to produce real injury
or to cause angry passions in either, do not in the least militate
against the view I have expressed ; for such encounters are neither
breaches of the peace nor are they calculated to be productive
thereof, but if, under color of a friendly encounter, the parties enter
upon it with, or in the course of it form, the intention to conquer
each other, by violence calculated to produce mischief, regardless
whether hurt may be occasioned or hot, as, for instance, if two men
72 Cases on Criminal Law.
pretending to engage in an amicable spar with gloves, really have
for their object the intention to beat each other until one of them
be exhausted and subdued by force, and so engage in a conflict
likely to end in a breach of the peace, each is liable to be prose-
cuted for an assault ; Reg. v. Orton, 39 L. T., 293. Whether an
encounter be of the character I have just referred to, or a mere
friendly game, having no tendency, if fairly played, to produce any
breach of the peace, is always a question for the jury in case of an
indictment, or the magistrates in case of summary proceedings.
The cases cited of alleged indecent assaults on young children
by their consent, are no authorities to the contrary ; and may all
be disposed of in this one observation, viz., that the indecent impo-
sitions of hands charged in those cases as assaults neither involved,
nor were calculated to involve, breaches of the peace, and, therefore,
being by consent, were not punishable as assaults, any more than
they would have been had the objects of them been for the most
innocent purposes. I think it wholly immaterial, in considering
cases of this description, to inquire by whom the first blow was
struck, for, as was said by Lindley, J., in Reg. v. Knock, 14 Cox
C. C, I, "the right of self-defence does not justify counter blows
struck with a desire to fight."
Upon the ruling of the chairman as to the illegality of the fight,
I entertain, therefore, no manner of doubt, and I am clearly of
opinion that the combatants themselves were each guilty of an
assault upon each other.'
STATE V. HARTIGAN.
Supreme Court of Vermont, i860.
32 Vermont, 607.
Kellogg, J. The information against the respondent in this
case contained two counts ; the first charging him with the com-
mission of the crime of rape upon one Orilla Vincent, and the
second charging him with an assault upon the same woman with
1 Accord: C. V. Collberg, 119 Mass., 350 (1875) ; St. v. Burnham, 56
Vt, 445 (1884).— Ed.
Cases on Criminal Law. 73
intent to commit rape upon her. On trial the respondent was
acquitted on the first count, and convicted on the second count.
The evidence on the trial is detailed in the respondent's excep-
tions, and the Court instructed the jury that if they found that the
respondent, upon the occasion when, as it was alleged and testified
to by the woman Vincent, each of the said crimes was committed,
laid hold of her person and pushed her, as stated in her testimony,
with the intention and for the purpose of having sexual intercourse
with her by force and against her will, and that she resisted for a
time, but ultimately yielded, they might find him guilty under the
second count, although they might find that the sexual connection
then had by him and her which followed, was with her consent.
The respondent excepted to the charge of the Court on this point.
Whatever might be our opinion respecting the sufficiency of
the evidence to warrant a conviction of the respondent on either
<;ount, our duty at this time is to be confined to the examination of
the errors assigned in the charge of the Court to the jury, to which
the respondent's exceptions exclusively relate. It is an assump-
tion of the very point in controversy to say that the facts given in
the evidence constitute one entire transaction, and that as the jury
have acquitted the respondent of the greater offence, he cannot be
convicted of a lesser one on testimony which was a part of the
-evidence introduced to establish his guilt of the greater offence.
The jury have found by their verdict that the respondent did, on
the occasion testified to, assault the woman with the intention and
for the purpose of having sexual intercourse with her by force and
against her will, and that she resisted for a time, although she
ultimately yielded. These facts are all which are essential to be
established in order to make out the proof that the crime was com-
plete. And we consider that the charge of the Court in respect to
the resistance of the woman referred by reasonable intendment to
a real resistance on her part, made in earnest and good faith, and
that the charge, so understood, was all which could be required on
that point.
But it is claimed that the subsequent yielding and consent of
the woman to the sexual intercourse which followed, has relation,
back to, and covers the preceding acts ; or, stated in equivalent
words, that the ultimate consent of the woman should have a retro-
active effect, by relation, and operate as a condonation of a crime
74 Cases on Criminal Law.
which had been complete. The rules of criminal law are not
founded upon legal fictions, and the doctrine of rela:tion, however
useful it may be as a rule defining or regulating private rights in a
civil suit, has no application in criminal proceedings. On this
point the rule, as stated in 3 Greenleaf's Evidence, Sec. 21 1, is that
if the woman was first violated and afterwards forgave the ravisher
and consented to the act, still the particular" offence in question
being committed by force and against her will at the time of its
commission, the crime is in legal estimation completed ; these cir-
cumstances being only admissible in evidence on the part of the
respondent to disprove the allegation of the want of consent. The
same rule is stated in i Russell on Crimes, 677, and also in Ros-
coe's Criminal Evidence, 860. It has never been regarded as a
legal excuse for the consummated offence that the woman consented
after the fact, and we regard this principle as being applicable to
the case of an assault with an intent to commit a rape, as well as
to the higher offence. It is, in our judgment, decisive of the ques-
tion raised in this case, and as we find no error in the instructions
given by the Court to the jury, the respondent's exceptions are
overruled. On the application of the respondent the case was
remanded to the county to pass sentence.
REX V. ROSINSKI.
Court for Crown Cases Reserved, 1824.
I Moody, 19.
The defendant was tried and convicted before Justice Bayley,
at the Lent Assizes for the County of Lancaster, in the year 1823.^
The third count was for a common assault. It appeared front
the evidence that the defendant pretended to be able to cure dis-
orders of all kinds. Ann Gibbons, the prosecutrix, applied to the
defendant to be cured of fits, when the defendant told her she
must strip naked. Upon the prosecutrix refusing to do this, the
defendant told her that she must or else he could not do her any
good. The prosecutrix then began to untie her dress, and the de-
fendant stripped off all her clothes ; she told him at the time she
^The first count is omitted:
Cases on Criminal Law. 75
did not like to be stripped in that manner, but said nothing more.
When she was stripped, the defendant rubbed her five or ten min-
utes with some stuff" from a bottle, and then bid her put on her
clothes, which she did, and went away. She said she did not put
off her clothes willingly, he made her.
From the prisoner's defense it seemed as if he wanted to dis-
cover if she had the menses about her at the time.
The learned Judge left it to the jury to say whether the
prisoner really believed that the stripping her could assist him in
enabling him to cure her.
The jury were satisfied he had no such belief, and that it. was
wholly unnecessary ; but the learned Judge doubted whether the
special count was good in law, and whether the making her strip
and pulling off her clothes was an assault, and reserved those points
for the consideration of the Judges. In Easter Term, 1824, the
Judges met and considered this case, and the conviction for the
common assault was held right.
COMMONWEALTH v. NICKERSON.
Supreme Judicial Court of Massachusetts, 1862.
5 Allen, 519.
Indictment under Gen. Sts. c. 160, § 30. The first count
charged that the defendants, three in number, on the fourth of
August, i860, at Nahant, committed an assault and battery upon
Charles A. T. Rice, and then and there without any lawful au-
thority, and without the consent and against the will of said Charles,
confined and imprisoned him for the space of two hours.
Dewey, J. The conviction of the defendants upon the first
count of this indictment may be well sustained. The evidence shows
an assault upon the person of C. A. T. Rice, and a restraint upon
his liberty. Every such restraint of the liberty of a person, if not
justified by law, is in the eye of the law a false imprisonment, for
which the party was liable to an indictment at common law. Com.
Dig. Imprisonment, G. ; 3 Chit. Crim. Law, 835. The like offence
is now made punishable by statute, under the provisions of Gen.
Sts. c. 160, § 30.
The only question upon this count arises upon the ruling of
76 Cases on Criminal Law.
the court upon that part of it which alleges that the assault and false
imprisonment were committed without the consent and against the
will of said C. A. T. Rice.
The instructions to the jury as to what would constitute a seiz-
ing and imprisonment against the will of the party were certainly
sufficiently favorable to the defendants, as they would exclude all
previous knowledge of their object or cooperation in forcibly tak-
ing the child from the custody and care of his teacher, on the part
of the child himself.
But in our opinion a more stringent ruling upon this point
would have furnished no legal ground for exception in matter
of law. The party seized and imprisoned was a child of tender
years. The legal custody and care of him was in his father. This
had been judiciously settled in proceedings instituted by the
mother asking for his custody. The adjudication settled the rights
of the parties as to the custody of the child, and rendered illegal
and criminal any attempt on the part of the mother or agents act-
ing under her to obtain by violence the possession of him.
Being in the actual custody of his father, whose will alone was
to govern as to his place of residence and the selection of a teacher
and custodian, the child of nine years of age was incapable of
assenting to a forcible removal from the custody of his teacher, and
a transfer to other persons forbidden by law to take such custody.
He was under illegal restraint, when taken away from the lawful
custody and against the will of his rightful custodian ; and such
taking is in law deemed to be forcible and against the will of the
child. This view is in accordance with that taken in the case of
State V. Farrar, 41 N. H., 53, upon a similar indictment. See also
State V. Rollins, 8 N. H., 550. It is always so held in cases heard
upon a habeas corpus issued upon the application of one of the
parents, alleging imprisonment and restraint of the child, and seek-
ing his restoration ; and in the case first cited, it was held equally
applicable to the case of an indictment for assault and imprison-
ment of a child of tender years.
The doctrine of the cases cited from the English reports, of
indictments for assaults upon female children, by indecent famil-
iarities to which they assented, and in which by reason of such
assent the acts done were held not to amount to assault, we think
should not be extended to cases like the present, where the abduc-
Cases on Criminal Law. yj
tion from the lawful custody of the father by violence and strong
hand is the substantial offence.^
Without limiting the precise age in which a child would be
held not to have the legal capacity to assent to such forcible abduc-
tion from the custody of the parent to whom such custody has
been assigned by an order of this Court, the forcible taking away
of a child of nine years of age, against the will of the father, or
those to whom his father had committed him for nurture or edu-
cation, will authorize a jury to find that the child was illegally
restrained of his liberty, whatever may have been his apparent
wishes or satisfaction in being withdrawn by force from his place of
legal custody, and, in the language of the law, " his place of legal
freedom," and placed under the care of those whose custody was
illegal restraint. The result is, therefore, that the verdict on the
first count is sustained, and judgment may be entered thereupon,
if the Attorney General shall enter a nol. pros, upon the other
counts.^
STATE V. COVINGTON.
.Supreme Court of South Carolina, 1832.
2 Bailey, 569.
This was an indictment under the Act of 1754, P. L., 236, for.
inveigling and stealing a slave named Dick, the property of Jacob
Suber, with a third count for aiding the said slave in running away,
&c. The jury, under charge of the Court, found the defendant
guilty ; and he now moved to set aside the verdict, and for a new
trial.
J. J. Caldwell and Banslett for the motion.
Thompson, Solicitor, contra.
Johnson, J.^ I come now to the consideration of, I think,
the most important question which arises out of the grounds of
' This doctrine is generally denied in the United States ; Singer v.
People, 13 Hun, 418; Commonwealth v. Roosnell, 143 Mass., 32; People v.
Stewart, 85 Cal., 174.
When consent is held to be a justification, force in malicious excess of
the consent will take away its justifying effect. Richie v. State, 58 Ind.,
355 (1877). -Ed.
^ Part of this case is omitted.
'Part of the opinion is omitted.
78 Cases on Criminal Law.
this motion. The owner, or rather his family in his absence, which
I regard as equivalent, knew of and had assented to the negro's
meeting the prisoner and arranging with him their plan of elope-
ment, and moving forward in the execution of it ; and the question
is, whether the owner, under the circumstances, can be said to be
"deprived of the use and benefit" of the slave-, within the meaning
of the Act.
In considering this question, it will be necessary to recur again
to the analogy between the crimes of inveigling, and stealing, a
slave, in relation to the effect on the owner, the loss of use and
benefit, for the purpose of applying the rules of law. In larceny,
the primary inquiry is, whether the taking were invito domino, or
without the will or approbation of the owner ; 2 East's P. C. 665,
and so of inveigling a slave. If, therefore, one consent that another
shall take his goods, or by his own act procure them to be taken,
such taking is not larceny. But I apprehend, that the knowledge
that they are to be taken, does not constitute evidence of such
consent or approbation. Thus, if one, who has goods exposed,
knows that a thief intends to take them, but neglect to watch or
secure them, this neglect is in some sort an assent to the taking
by the thief; but the act is not in pursuance of the will, or appro-
bation of the owner, but the voluntary act of the thief A few
cases will serve to illustrate the principle.
In McDaniel's case, 2 East's P. C, 665, one Salmon had con-
spired with McDaniel and other persons, to procure himself to be
robbed by two others, who were ignorant of the design, for the
purpose of procuring the reward given by Act of Parliament for
apprehending robbers on the highway ; and it was held that the
robbery, under such circumstances, did not constitute felony.
The obvious reason is, that the act was procured to be done by
the party complaining, and in pursuance of his will and approbation.
But in Norden's case, 2 East's P. C.,666, where one knowing
that a highway robber frequented a particular place, put himself in
his way, and upon being attacked by the highwayman gave him his
money, and afterwards seized him, it was held to be robbery in
the highwayman ; for the act was not procured by the prosecutor
nor done according to his will, but proceeded from the voluntary
act of the prisoner.
Eggington's case, 2 East's P. C, 666, bears even a more
Cases on Criminal Law.. 79
striking analogy to the present. There, the prisoner and some
others, intending to rob one Boulton's manufactory at Soho, had
applied to one Phillips, his servant, who was employed there as a
watchman, to assist in the robbery, and Phillips assented, but soon
after gave information to Boulton, who assented to his carrying on
the business, and to his leaving open the door leading to the front
yard, and to his being with the prisoners the whole time. One
hundred and fifty guineas and some silver ingots, marked for the
purpose of identity, were left in the counting house ; and a majority
of the Court were of opinion, that the taking, under these circum-
stances, was larceny. Lawrence, J., doubted ; but the reasoning
of the Court is, to my mind, perfectly satisfactory. They thought
there was no assent on the part of Boulton. That his object being
to detect the prisoners, he only gave them a greater facility to commit
the larceny, than they otherwise might have had; and that this could
no more have been considered as his assent, than if a man, know-
ing of the intent of thieves to break into his house, were not to
secure it with an unusual number of bolts. The design having orig-
inated with the prisoners, it could only be considered as an
apparent assent on the part of Boulton.
Of the sime character, and alike analogous, is the case of
Stroud, reported in a note in 2 Brev. Dig., 249, upon the authority
of which very many cases have since been adjudged. That was a
prosecution founded on the Act of the Legislature imposing a
penalty on anyone who should deal or traffic with a slave, without
a written ticket or permit from the owner ; and it was held, that
the offence was consummated, although the trading was done by
the slave in pursuance of the instructions of the owner, and in his
presence, when the accused was ignorant of such instructions and
presence. This, like Eggington's case, being a contrivance to
detect the offender.
The principle inculcated in these cases appears to me to have
a direct application to the case in hand. Every act of the prisoner
proceeded from his own mere motion, without any agency on the
part of the owner of the slave. His not preventing the thing,
when he knew of it beforehand, is not evidence of the assent of his
will, but is only an apparent assent. The act was therefore invito
domino, and constituted felony.
O'Neall, J., concurred. Motion refused.
8o Cases on Criminal Law.
SPEIDEN V. STATE.
Court of Appeals of Texas, 1877.
3 Texas Appeals, 1 56.
White, J.^ As disclosed in the record the facts are substan-
tially as follows :
Pinkerton's detective agency, at Chicago, Illinois, obtained, by
some means, a number of letters and postal cards written by the
defendant, from Dallas, to a friend in Chicago, urging him to come
to Dallas and join him in breaking into and robbing some of the
banks in the latter city. It appears that Pinkerton forwarded those
letters to John Kerr, a banker of Dallas, who immediately called a
meeting of the bankers of the city and submitted the matter to
them. The result of this meeting was that the bankers requested
Pinkerton to send a detective to Dallas to work up the case. Deroso,
a sergeant of Pinkerton's force, came, and, after an interview with
the bankers, sent back to Chicago for Wood and McGuire, two
detective aids, who were to represent themselves to the defendant
as professional burglars and induce him to enter some bank build-
ing in the night time, when they would procure his arrest.
After the arrival of Wood and McGuire they set to work to
carry out this plan, keeping in constant communication with Deroso,
and, through him, with the bankers, who were kept constantly in-
formed as to the plans and movements of the parties. Finally it
was agreed on all hands that the banking house of Adams & Leon-
ard should be broken into on Sunday night. Adams & Leonard
agreed to the arrangement, and the detectives were, in the adven-
ture, working in their employ.
Pursuant to the plan agreed upon, Deroso, Hereford, a deputy
sheriff of Dallas county, a Mr. Mixon, United States Deputy Mar-
shal, and another party entered and took possession of the bank
during the daytime, about two or three o'clock on Sunday, to re-
main therein until the burglary was effected and the defendant was
arrested. About one o'clock at night the back door of the bank
was forced open by the two detectives. Wood and McGuire, who
came in, spoke to the concealed parties, and went into the vault,
1 Only so much of the opinion as relates to consent is printed.
Cases on Criminal Law. 8r
wheri, after remaining about an hour, Wood went out, told Speiden,.
the defendant, that they wanted more help, and returned in a short
time, and, coming in, closed the door after him. In a minute or
two Speiden came in and closed the door, when the ofificers arrested
him.
Now, as to the law of the case : To our minds it is clear that
Deroso and the other detectives were the servants and agents of
Adams & Leonard, and had full authority to consent to defendant's
entry into the bank, and that his entry was not only with their con-
sent, but at their solicitation. The case is somewhat like that of a
man being robbed by his own consent, although the supposed rob-
bers did not know of the consent. Reanes' Case, 2 East, 734 ;
McDaniel's Case, Fost. 121.
In Tennessee, where the prisoner had arranged with a negro,
during the days of slavery, to steal him, and the negro informed
his master, who told him to carry out the agreement between the
prisoner and himself, which was done, and the prisoner was arrested
in the act, it was held that, to constitute larceny of a slave, it must
appear that the accused had possession of the slave, and that the
possession was obtained without the consent of the owner. Kemp
V. The State, 1 1 Humph., 320.
Mr. Bishop says : The cases of greatest difficulty are those in
which one, suspecting crime in another, lays a plan to entrap him ;
consequently, even if there is a consent, it is not within the knowl-
edge of him who does the act. Here we see * * * that,
supposing the consent really to exist, and the case to be one in
which, on general doctrines, the consent will take away the crimi-
nal quality of the act, there is no legal crime committed, though
the doer of the act did not know of the existence of the circum-
stances which prevented the criminal quality from attaching.
* * * A common case is that of burglars who, intending to
break into a house and steal, tempt the servant of the occupant to
assist them, and the servant, after communicating the facts to his
master, is authorized to join them in appearance. Under such cir-
cumstances, clearly, the burglars are not excused for what they do
personally ; but, it seems, if the servant opens the door while they
enter they are not held criminal for this breaking thus done by the
servant, acting under command of the occupant of the house
broken." i Bishop's Cr. Law, sec. 262 ; see also sec. 263.
82 Cases on Criminal Law.
The case of Regina z^. Johnson and Jones, i Car. & M. 41
Eng. C. L. R. 123, is in point. In that case the court say : " Cole,
the groom, it is true, appeared to concur with the prisoners in the
commission of the offence. But in fact he did not really concur
with them, and he, acting under the direction of the police, must
be taken to have been acting under the direction of Mr. Drake, the
prosecutor. Under the circumstances of this case the prisoners
went into a door which, it seems to me, was lawfully open. There-
fore neither of them was guilty of burglary."
In Eggington's case, which is'also in point, it was held " that no
felony was proved, as the whole was done with the knowledge and
assent of Mr. Boulton, and the acts of Phillips (the servant) were his
acts." 2 East, 666.
Another case in point is Allen v. The State, the substance of
which is that, "when the proof showed that the prisoner proposed
to a servant a plan for robbing his employer's office at night,
that the servant disclosed the plan to his employer, by whom it
was communicated to the poHce ; that the master, acting under
the instructions of the police, furnished the servant with the keys
of his office on the appointed night ; that the servant and the pris-
oner went together to the office, when the servant opened the door
with the key, and both entered through the door, and were arrested
in the house by the police ; held that there could be no conviction
of burglary." 40 Ala., 344. See also 2 Whart. Cr. Law, sec. 1 540 ;
Roscoe's Cr. Ev. 345.
In the case at bar the detectives cannot be considered in
any other light than as the servants and agents of the bankers,
Adams & Leonard. They, the detectives, had the legal occupancy
and control of the bank ; two of them made arrangements with
defendant to enter it ; and defendant, when arrested, had entered
the bank at the solicitation of those detectives, who were rightfully
in possession, with the consent of the owners. This cannot be
burglary in contemplation of law, however much the defendant
was guilty in purpose and intent.
The judgment of the lower court must be reversed and the
cause remanded.
Reversed and remanded.
Cases on Criminal Law. 83
STATE V. ABLEY.
Supreme Court of Iowa, 1899.
109 Iowa, 61.
Indictment for breaking and entering a store building. From
a judgment of conviction the defendant appeals. — Modified.
Taylor & Evans and E. P. Andrews for appellant.
H. C. Liggett, J. H. Scales, Milton Remley, Attorney General,
and Charles A. Van Vleck for the State.
Waterman, J. The building entered was owned by the firm of
Schaeffer & Reynolds. No question is made but that defendant broke
and entered the store, and took goods therefrom ; but it is claimed that
he cannot properly be convicted of the offense charged, because the
entry was made with the assent of the owners or their agent. The
facts upon which this claim is based are as follows : One Clock was
marshal of the town in which the building was located. Prior to the
commission of the crime. Clock (as he claims, for detective pur-
poses) had been counselling and advising with defendant, not only in
relation to this particular offence, but also as to the two breaking
and entering other buildings. So zealous was the officer in this
questionable line of duty and so anxious was he to impress defend-
ant with the belief that he was earnest in his criminal intentions and
would keep faith in the matters plotted, that Clock alone on one
occasion broke and entered another store building, belonging to one
Bryan, with a key furnished by defendant, and took from it some
goods. Of course, he claims that this was done merely to lead
defendant on. Clock testifies that the mayor of the town had pre-
vious information from him of defendant's intention to enter the
Bryan store. The mayor, who was a witness, does not testify on
this point ; but, however that fact may be. Clock admits that Bryan,
the owner, had no such information, and that the entry was effected
without his knowledge or consent. One Will Reynolds, a clerk in
the employ of Schaeffer & Reynolds, had a key to the building in
■question in this gase. Shortly before the commission of the offence
charged, Clock borrowed this key to get an impression from which
defendant could make another key which would open the door, and
such a key was afterwards made by defendant. At this time Clock
told Reynolds, the clerk, the use which he wished to make of the
84 Cases on Criminal Law.
borrowed key, and also of defendant's criminal purpose. The
breaking and entering were done in the night time. During the
day Clock had warned several citizens of the contemplated crime
— among others, Schaeffer, a member of the firm which owned the
store. He told Schaeffer that defendant had a key to the store, and
would enter it that night. He did not, however, tell him where or
how the key had been obtained. The persons so warned were
requested to be on guard and assist in defendant's arrest after the
offence was completed. This plan was carried out. Schaeffer and
the others watched. Clock and defendant came upon the scene
about midnight. Defendant opened the door and entered the store.
Clock following. As they came out with the property taken,
defendant was arrested.
One who has committed a criminal act is not entitled to be
shielded from its consequences merely because he was induced to
do so by another. If there is anything in the defense here, it must
be because the entry was assented to by Schaeffer. But the evidence
tends strongly to show that Schaeffer, though not objecting, did not
personally assent. One who knows of a crime contemplated against
him may remain silent and permit matters to go on, for the purpose
of apprehending the criminal, without being held to have assented
to the act. People v. Liphardt, 105 Mich., 80 (62 N. W. Rep.,
1022); State V. Adams, 115 N. C, 775 (20 S. E. Rep., 722) ;
State V. Sneff, 22 Neb., 481 (35 N. W. Rep., 220); Thompson v.
State, 18 Ind., 386; States. Jansen, 22 Kan., 498. The question
of the owner's personal assent was left to the jury, and, we think,
under instruction that fully and accurately stated the law. But cer-
tain instructions were asked by defendant and refused by the Court,
the thought of which was to predicate the assent of the owner upon
the acts of the clerk, Reynolds. The evidence does not show on
the part of the members of the firm any knowledge of Reynolds
conduct. Of course, if the clerk, with criminal intent, aided in any
way in the entry of this building, he would be a party to the crime.
But that is not what is claimed by defendant. He contends
that if the clerk, though without criminal intent, assented to the
entry, such assent will be imputed to the master. Some text writ-
ers lay down the rule in terms broad enough to give support to this
contention, and the following cases are cited by counsel as sustain-
ing it : Reg. v. Johnson, 41 E. C. L., 123 ; People v. Collins, 53
Cases on Criminal Law. 85;
Cal., 185 ; Saunders v. People, 38 Mich., 218 ; People v. McCord,
76 Mich., 200 (42 N. W. Rep., 1106) ; Allen v. State, 40 Ala.,
344. In the California case, the agent of the owner, who was pre-
tending to take part in the burglary, alone entered the building,
and the decision was founded on this fact. The other cases are each
based upon one of two states of fact : Either the servant had
custody of the building and a right to open it at the time he did, or
at the time he assented thereto, or the owner was aware of the part
the servant was taking, and acquiesced therein. Neither of these
conditions prevailed in the case at bar. It does not appear that
Reynolds had charge of the building, or had any right to admit
persons therein, after it was closed for the night; and as we have said,
his conduct in the transaction with Clock was unknown to the own-
ers. We do not think the clerk's conduct can be used as a shield
for defendant, i Bishop Criminal Law (5th ed.), section 262 ;
State V. Jansen, 22 Kan., 498. The instructions were rightly
refused.'
We cannot leave this case without again, and in more emphatic
terms, expressing our disapproval of the conduct of Clock, who, if
he did not suggest, at least encouraged the commission of the offence
by defendant. We are inclined to doubt whether defendant, if left
to himself, would have perpetrated the crime of which he has been
convicted. Clock stimulated him with advice, aided him by acts,
and, through unremitting effort, spurred him on to his undoing.
This conduct was outrageous, if, indeed, it was not criminal, and it
is aggravated, rather than excused, by the fact that Clock was a
peace officer. Frail human nature is prone enough to crime ; it
should not be purposely tempted ; and in this case it was urged to
act. Defendant was sentenced to imprisonment in the penitentiary
for a term of three years. In view of the facts we shall reduce the
term to six months.
With this modification, the judgment will be affirmed?
' Part of the opinion, dealing with a question of evidence, is omitted.
^See also St v. West, 157 Mo., 309 (1900) ; Dalton v. St., 113 Ga.,
1037 (1901). — Ed.
86 Cases on Criminal Law.
EFFECT OF CONSENT, ETC. (Conlinued.)
(6) Consent of the State.
If two play at barriers, or run a tilt without the King's com-
mandment, and one kill the other, it is manslaughter ; but if by
the King's command, it is not a felony, or, at most, per infortuniam.
1 1 H., 7, 23 ; B. Coron., 229 ; Dklton, Cap. 96 ; Co., P. C, p. 56 ;
Hale, P. C, 473.
REGINA V. LESLEY.
Court for Crown Cases Reserved, i860.
8 Cox C. C, 269.
Case reserved by Watson, B., at the Christmas Assizes at
Liverpool.
The prisoner was the master of the British ship " Louisa
Braginton," and the charge against him was for the false imprison-
ment of several Chilian subjects during a voyage from Valparaiso
to Liverpool.
These persons having been ordered to be banished from Chili
by the Government of that country, were brought by force,
guarded by soldiers of that State, on board the ship, whence the
pHsoner, under a contract (a copy accompanies this case) with the
Chilian Government, carried and conveyed these Chilian subjects
to Liverpool.
On this evidence I directed a verdict of guilty, reserving the
question of law, whether or not the defendant was liable to an
indictment in this country, under the circumstances, for the opinion
of this court.
W. H. Watson.i
Earle, C. J. In this case the question is, whether a convic-
tion for false imprisonment can be sustained upon the following
facts : The prosecutor and others being in Chih, and subjects of
^The indictment, evidence and argument of counsel are omitted.
Cases on Criminal Law. 87
that State, were banished by the Government from Chili to England.
The defendant, being master of an English merchant vessel lying
in the territorial waters of Chili, near Valparaiso, contracted with
that government to take the prosecutor and his companions from
Valparaiso to Liverpool, and they were accordingly brought on
board the defendant's vessel by the officers of the Government,
and carried to Liverpool by the defendant under his contract.
Then can the conviction be sustained for that which was done in
Chilian waters ? We answer, no. We assume that in Chili the act
of Government towards its subjects was lawful ; and although an
English ship in some respects carries with it the laws of her country
in the territorial waters of a foreign State, yet in other respects it
is subject to the laws of that State as to acts done to the subjects
thereof. We assume that the Government could justify all that it
did within its own territory, and we think it follows that the defend-
ant can justify all that he did there as agent for the Government,
and under its authority. In Dobree v. Napier, 2 Bing., N. C,
781, the defendant, on behalf of the Queen of Portugal, seized
the plaintiff's vessel for violating a blockade of a Portuguese port
in the time of war. The plaintiff brought trespass, and judgment
was for the defendant, because the Queen of Portugal in her own
territory had a right to seize the vessel and to employ whom she
would to make the seizure, and therefore the defendant, although
an Englishman, seizing an English vessel, could justify the act under
the employment of the Queen. We think that the acts of the
defendant in Chili become lawful on the same principle, and are
therefore no ground for the conviction. The further question
remains, can the conviction be sustained for that which was done
out of the Chilian territory? and we think that it can. It is clear
that an English ship on the high seas, out of any foreign territory,
is subject to the laws of England, and persons, whether foreign or
English, on board such ship are as much amenable to English law
"It is not pretended that there was a law of our State authorizing the
killing of a male of that tribe, and the proclamation or order of any officer of
the State could not make that right which is wrong, or legal which is illegal.
If such a proclamation or order was made, and if on account thereof any
ignorant person was misled into the commission of crime, it is for the Gov-
ernor to determine whether that would be a proper case for the exercise of
executive clemency." Wilson, C, J., in St. v. Gut, 13 Minn., 341 (1868).
88 Cases on Criminal Law.
as they would be on English soil. In Reg. v. Sattler (7 Cox Crim.
Cas., 431), this principle was acted on so as to make the prisoner,
a foreigner, responsible for murder on board an English ship at
sea. The same principle has been laid down by foreign writers on
international law, among which it is enough to cite Ortolan sur la
Diplomatie de la Men, liv., 2, Cap. 13. The Merchant Shipping
Act (17 and 18 Vict, c. 104, s. 267), makes the master and seamen
of a British ship responsible for all offences against property or
person, committed on the seas out of Her Majesty's dominions, as
if they had been committed within the jurisdiction of the Admiralty
of England. Such being the law, if the act of the defendant
amounted to a false imprisonment, he was liable to be convicted.
Now, as the contract of the defendant was to receive the prose-
cutor and the others as prisoners on board his ship, and to take
them without their consent over the sea to England, although he
was justified in first receiving them in Chili, yet that justification
ceased when he passed the line of Chilian jurisdiction, and after
that it was a wrong which was intentionally planned and executed
in pursuance of the contract, amounting in law to a false imprison-
ment. It may be that transportation to England is lawful by the
law of Chili, and that a Chilian ship might so lawfully transport
Chilian subjects, but for an English ship the laws of Chili out of
the State are powerless, and the lawfulness of the acts must be tried
by English law. For these reasons, to the extent above mentioned,
the conviction is affirmed.
Conviction affirmed.
CITY OF EVANSTON v. MYERS.
Supreme Court of Illinois, 1898.
172 Illinois, 266.
Mr. Justice Wilkin delivered the opinion of the Court.^
The Appellate Court, in passing upon this case, found that
the beer was sold as alleged in the complaint, but held that, inas-
much as the city furnished the money and the purchaser was in
its employ to discover violators of the ordinance, the offense was
one induced by the city of Evanston, and the defendant was not
' Thfropinion onlyisprinted.
Cases on Criminal Law. 89
punishable therefor. Under the facts of the case, as we understand
vthem, we cannot concur in this view. The offense, if one was com-
initted, consists in the unlawful selling of intoxicating liquor. The
"defendant was passing through an alley in Evanston with a load of
beer when Denvir hailed him, asking, " How is it for a case of
Taeer? " to which he replied, " It is all right." The money was
paid and the beer handed out. It is clear that Denvir, in making
this purchase, used no fraud, deceit, or inducement other than a
willingness to buy. It also appears, uncontradicted, that appellee
had sold beer to Denvir at other times, in violation of the ordinance
in question. On this occasion he was willing to do so again. The
-offense of selling the beer having been voluntarily committed, is it
reasonable to say that the willingness of Denvir to purchase, for
"whatever purpose or object, constitutes a sufficient inducement to
appellee to make the sale, so as to excuse the act? We think
not. The offense consisted, not in the buying, but in the selling
of the beer.
A number of cases are cited to sustain the theory of the
appellee's defense, but in those cases the criminal acts charged
were not wholly voluntaiy on the part of the defendant, but were
induced, in some measure, by the acts and conduct of the prosecut-
ing witnesses. The principle here involved is well announced in
the case of Grimm v. United States, 156 U. S., 604. In that case
-a postoffice inspector suspected Grimm of being engaged in the
business of selHng obscene pictures and sending them through the
mails. Under assumed names the inspector wrote for a supply of
the pictures, and received them from defendant. In defense of the
charge made against him, defendant insisted the conviction
should not be sustained because the letters were deposited in
the mails at the instance of the government and through the solic-
itation of one of its officers. Upon this point the court said : "It
does not appear that it \Vas the purpose of the postoffice inspector
to induce or solicit the commission of a crime, but it was to ascer-
tain if the defendant was in an unlawful business. * * * jj^g
law was actually violated by the defendant. He placed letters
in the postoffice which conveyed information as to where
obscene matter could be obtained, and he placed them there
with a view of giving such information to the person who should
receive those letters, no matter what his name ; and the fact that
90 Cases on Criminal Law.
the person who wrote under these assumed names and received his
letters was a government detective in no manner detracts from his
guilt." See the cases there cited.
In the case at bar it may be truly said it does not appear that
it was the purpose of the city of Evanston to induce or solicit the
unlawful selling of beer within its limits, but to ascertain whether
the ordinance was being violated in that regard. The appellee
committed the act charged against him, deliberately and voluntarily,
and in such a manner as to indicate that he would have sold beer
to any other person applying for it. We think no element is want-
ing on the part of appellee in this case to bring this act within the
letter and spirit of the ordinance. The position of appellee is not
that he is innocent of the offense charged, but that his guilt was
proven on the trial by evidence obtained in an objectionable man-
ner by the city. This is a matter of which he has no right to com-
plain.
Other points insisted upon by counsel for appellee have been
duly considered, but we find no substantial merit in them.
The judgments of the Criminal Court and Appellate Court
will be reversed, and the case will be remanded to the Criminal
Court.
Reversed and remanded}
EFFECT OF CONSENT, ETC. {Continued.)
{c) Negligence of the Person Injured.
REX V. WATERS.
Old Bailey, 1834.
6 Carrington and Payne, 328.
The prisoner was charged with the manslaughter of John
Slee, on the coroner's inquisition, the grand jury having ignored
the bill.
^Compare U. S. v. Adams, 59 Fed., 674 (1894) ; Armstrong v. St. 47
S. W. ,981 (1898).— Ed.
Cases on Criminal Law. 91
It appeared that the prisoner was a seaman on board a
schooner lying in the river Thames, and the deceased was a person
in the habit of going about in a boat among the ships in the Pool
selling spirits, purl, hot beer, &c., and that, on the day in question,
the prisoner and he had some dispute about paying for some
spirits, and, both being intoxicated, a good deal of rough joking
had taken place between them. The first witness for the prose-
cution swore that the deceased's boat being alongside the
schooner, the prisoner pushed it with his foot, and the deceased
stretched out over the bow of the boat to lay hold of a barge to
prevent the boat from drifting away, and, losing his balance, fell
overboard, and was drowned.
Payne, for the prisoner, submitted that this was not a case
of manslaughter.
Park, J. inquired of the coroner, who was on the bench,
whether there was any other witness who could carry the case
further, and being informed by him of the name of one, called him
into the box and examined him ; but he swore that it was another
man, and not the prisoner who pushed the boat away.
Park, J. after consulting with Mr. Justice Patteson, said
that his learned brother and himself were of opinion, that, if the
case had rested on the evidence of the first witness, it would not
have amounted to a case of manslaughter ; but that, as it now
stood, of course the prisoner was entitled to an acquittal.
Verdict, not guilty.
REGINA V. WILLIAMSON.
Central Criminal Court, 1844.
I Cox C. C, 97.
The prisoner was indicted upon the coroner's inquisition,
which charged that he, within the jurisdiction of the Central
Criminal Court, and within the limits of the 7 & 8 Geo. 4, c. 75
(private Act), feloniously, wilfully, and unlawfully did allow a cer-
tain boat called a skiff, belonging to one John Williamson, then
being a freeman of the Watermen's Company, to ply for hire at a
92 Cases on Criminal Law.
certain public stairs and plying place, that is to say, at London-
bridge-stairs, in the parish, &c., aforesaid, for the carrying of per-
sons and passengers for hire, within the limits of the said Act,
without a license having being granted, according, &c. ; and that
he, the said prisoner, being in and on board the said boat, without
such license as aforesaid, at the public stairs aforesaid, feloniously,
wilfully, and unlawfully did use and work the said boat without
such license as aforesaid, and that he then and there feloniously,
wilfully, and unlawfully did embark in and on board of the said
boat then and there being, without such license as aforesaid, him,
the said deceased, and divers, to wit, ten other persons, as pas-
sengers, for gain and hire, and the said prisoner and the said
deceased, and said ten other persons so being there in and on
board the said boat, without such hcense as aforesaid, he, the said
prisoner, did then and there feloniously, wilfully and unlawfully
use, navigate, and work the said boat, without such license as
aforesaid, in and on the waters of the said river Thames, the said
boat being then and there overloaded, and unfit from its frame,
dimensions, and construction, for the conveyance of more than four
persons as passengers therein, and that the said boat so being
without such license as aforesaid, and the said deceased and the
said several other persons then and there being therein as afore-
said, and the said prisoner then and there also being therein, and
having the control, conduct, and management thereof, was, then
and there, by the force and violence of the said waters, and through
the negligence, recklessness, want of skill, and proper caution of
him, the said prisoner, and by the overloading of the said boat as
aforesaid, upset and turned over in the said waters of the said river
Thames, by which said upsetting and turning over of the said boat,
he, the said deceased, was then and there precipitated into and
immersed, suffocated and drowned in the waters of the said river
Thames, of which said suffocation and drowning the said deceased
then and there died, &c.^
The evidence adduced was to the effect that thirteen indi-
viduals, children and grown persons, embarked in the boat, besides
two watermen, of whom the prisoner was one. Two of the wit-
nesses deposed, that by the swell of a steamer in motion the boat.
' The evidence relating to another point is omitted.
Cases on Criminal Law. 93
was carried against tiie bows of another steamer lying alongside
the landing-place ; that as soon as it struck, the prisoner called
out to the passengers to sit still, but instead of doing so, they all
jumped up and tried to lay hold of the steamer, and in consequence
the boat was overset. Had the passengers remained quiet, the
witnesses believed the accident would not have happened.
Another witness gave it as his opinion that the fault lay in
the prisoner's pushing off the boat from the stairs with one of the
oars, he standing upright at the time, instead of being seated, and
having the command of the sculls. He ought to have known the
danger, under such circumstances, of crossing the strong tide that
rushed through the arch of the bridge. But for his pushing off as
he did, the boat would have cleared the steamer. He thought the
same thing might have happened to the boat if there had been
only three persons in it, or even one.
Balantine and Wilde objected that on this evidence the
prisoner could not be found guilty. If, as was stated, the mere
pushing off the boat, he being then standing, was the cause of the
accident, it was not so gross a want of skill as could be cognizable
in a criminal court. Again, the inquisition states that the death
resulted from the overloading of the boat, but there is no evidence
whatever of this being the immediate cause of its sinking. One
witness asserts that it would have been, in all probability, driven
against the steamer had only two or three persons been on board,
and the others declare that if it had not been for the sudden rising
of the passengers and their attempting to catch at the steamer, the
casualty would not have taken place at all.
Williams, J. The words of the inquisition are, that
the prisoner, " through his negligence, recklessness, and want of
skill and proper caution, and by the overloading of the said boat,
&c., committed the injury." If any one of these causes is proved,
it will be sufficient. If the circumstance of the passengers jumping
up really caused the accident, the overloading of the boat was
immediately productive of such a result, and thus the prisoner is
answerable, for he should have contemplated the danger of such a
thing happening. If the fact of the defendant standing up in the
boat was the cause of the catastrophe, then it may be gross neg-
ligence on his part to have done so, because he is supposed to be
acquainted with the force and velocity of the tide, and the danger
94 Cases on Criminal Law.
of crossing it under the circumstances. On the whole, it is a
question for the jury whether the deceased met his death either by
the gross carelessness of the prisoner in the management of the
boat, or in taking on board, in the first instance, a greater number
of passengers than it was safely capable of carrying.
Not guilty.
REGINA V. LONGBOTTOM.
Norfolk Circuit, 1849.
3 Cox C. C. 439.
The indictment charged, that the two prisoners feloniously
killed and slew John Truman, by driving over him with a gig.
O'Malley and E. Rodwell, for the prosecution, proved that the
two prisoners, who lived in Ipswich, had gone to Bentley on the
day named in the indictment in a gig, and that on their return at
night they were observed to be in a state of partial intoxication.
At several places they drove along the high road at a very rapid
pace, and when they got within two miles of Ipswich they met
three men. At that time they were laughing and driving rapidly
down a hill, the top of which was thickly, shaded with trees. When
the three men got to the trees they found a man lying insensible
in the middle of the road, presenting all the appearance of having
been just run over by some vehicle. They took up the man, who
shortly afterwards died. On inquiry it turned out that the deceased
was a man who had been deaf from childhood, but had, in spite of
his infirmity, contracted an inveterate habit of walking at all hours
in the middle of the road. Against the probable consequences of
an indulgence in this habit he had been frequently warned, but
without effect.
D. D. Keane, for the prisoner Longbottom, submitted, at the
close of the case for the prosecution, that he ought to be acquitted,
inasmuch as it appeared that the deceased had contributed in a
great measure, if not altogether, to his own death by his own obsti-
nacy and negligence. There was, moreover, no proof that the
prisoners were driving at any extraordinary pace ; while it appeared
that they were in the middle of the road, and that the deceased
was walking just where he ought not to have been, reference being
Cases on Criminal Law. 95
had to the lateness of the hour, the darkness of the place, and his
peculiar infirmity, which ought to have induced him to refrain
from the selection of the most frequented part of the high road, as
that on which alone he would walk. No accident could possibly
have occurred to the deceased, if he had been at the side of the
road where foot passengers always walked. He had, therefore,
contributed to his own death, and the question was, whether that
fact did not exonerate the prisoners from such a charge as the
present. This might be tested. by analogy with a civil action under
Lord Campbell's Act. Under that statute the representatives of
the deceased could not maintain an action for compensation against
the prisoners, as he had himself been guilty of negligence ; so, in
this prosecution, it was contended that the prisoners could not be
convicted of the crime of manslaughter.
RoLFE, B. I cannot stop the case ; for whatever may have
been the negligence of the deceased, I am clearly of opinion that
the prisoners would not be thereby exonerated from the conse-
quences of their own illegal acts, which would be traced to their
negligent conduct, if any such existed. I am of opinion that if any
one should drive so rapidly along a great thoroughfare leading to a
large town, as to be unable to avoid running over any pedestrian
who may happen to be in the middle of the road, it is that degree
of negligence in the conduct of a horse and gig which amounts
to an illegal act in the eye of the law ; and if death ensues from
the injuries then inflicted, the parties driving are guilty of man-
slaughter, even though considerable blame may be attributed to
the deceased. I do not at all recognize the analogy which has
been put with regard to an action under Lord Campbell's Act and
a charge of felony ; and I abstain from giving any opinion as to the
question whether, under the circumstances here proved, the repre-
sentatives of the deceased would be precluded from maintaining an
action for compensation against the prisoners. But there is a very
wide distinction between a civil action for pecuniary compensation
for death arising from alleged negligence and a proceeding by way
of indictment for manslaughter. The latter is a charge imputing
criminal negligence, amounting to illegality ; and there is no balance
of blame in charges of felony, but wherever it appears that death
has been occasioned by the illegal act of another, that other is
guilty of manslaughter in point of law, though it may be that he ■
96 Cases on Criminal Law.
ought not to be severely punished. If the jury should be of opinion'
that the prisoners were driving along the road at too rapid a pace,
considering the time and place, and were conducting themselves in
a careless and negligent way in the management of the horse
entrusted to their care, I am of opinion that such conduct
amounts to illegality, and that the prisoners must be found guilty
on this indictment, whatever may have been the negligence of the
deceased himself.
Verdict, guilty}
Sentence : Eight months' imprisonment.
D. Power was counsel for the other prisoner.
EFFECT OF CONSENT, ETC. {Continued.)
id.) Guilt of the Person Injured.
REX V. WEBSTER.
King's Bench, 1789.
3 Term Reports, 388.
A rule had been obtained calling upon the defendant, who
was a justice of the peace for the county of Devon, to show cause
'Accord : Rex v. Hutchinson, 9 Cox C. C, 555 (1864); Reg. v. Kew, 12
Cox C, C, 355 (1872). See also C. v. Boston & L. R. Corp., 134 Mass., 211
(1883). Contra. Reg. v. Birchall, 4 F. & F., 1087 (1866).— Ed.
' ' In Reg. V. Desvignes, tried before Denman, J. , at the last session of
the Central Criminal Court, the defendant was charged with the manslaughter
of Sarah Ballard, on the night of the twenty-fourth of July last, by so negli-
gently managing a steam launch that a skiff containing the deceased and
other persons was run down and capsized, and her death caused by drowning.
In opening the case, the counsel for the prosecution laid it down broadly, that
although contributory negligence would be an element in favor of the defend-
ant in a civil case, it was no answer to a charge of manslaughter. Mr. Justice
Denman said : ' There is one decision to the contrary (Reg. v. Birchall, 4
F. & F., 1087. Ed.) but I grant that current authority is in the direction you
mention. The point, however, has never been settled in the Court of
Appeal.' "— L. T., Vol. 70 (Old Series), p. 76 (i88o).
Cases on Criminal Law. 97
why an information should not be exhibited against him for having
improperly convicted a person for killing a hare, the conviction
having been afterwards quashed at the Quarter Sessions. The
party applying for the information charged the defendant with very
gross misconduct : but
Bearcroft, who now showed cause, took a preliminary objec-
tion to the Court's entering into the merits, because the party con-
victed, who applied for the information, had not made any affidavit
of his being a qualified person, and that he had taken out a cer-
tificate. And he contended that it was the constant practice of
the Court to refuse applications of this sort for acts of injustice
done to individuals under pretense of certain improper acts done
by them, unless those persons made an exculpatory affidavit
denying the fact with which they were charged, as in the case of
libels.
Erskine and Fanshaw contended that that was not necessary
in a case like the present. This application is not made on
account of the injury done to the individual, but on account of
the injury done to the public, in a gross abuse of a judicial duty.
And whatever might be the acknowledged demerits of the suffer-
ing party, still the crime was the same in the magistrate, who
acted in open violation of his duty. The case of libels is different
from the present, because that concerns the individual alone who
is the object of it ; but this concerns the general administration of
justice, in which every person is interested.
Lord Kenyon, Ch. J. The question is not whether the doors
of justice shall be stopped, but whether justice shall be approached
by this particular avenue. If the defendant has acted improperly,
however guilty the party applying might be of the charge which
was imputed to him, there are other ways open to him for redress.
But we cannot interfere in this particular manner, according to
the established rules of the Court, without an affidavit from the
party complaining that he is innocent of the fact with which he
was charged. I remember an application of this sort made many
years ago against Sir John Fielding, for having issued a warrant
against one Bernard, upon a charge against him [not upon oath]
by the Duke of Marlborough, for sending threatening letters to
extort money from the Duke. But the information was denied
for want of such an exculpatory affidavit from Bernard.
98 Cases on Criminal Law.
AsHHURST, J., agreed, and mentioned several instances where
the Court had required exculpatory affidavits from persons who
applied for informations for hbels, Vid. R. v. Miles, Dougl. 271,
and R. v. Haswell & Bate, Dougl. 372, and had refused to interfere
because they were not made. Those cases, he thought, could not
be distinguished from the present on principle, because the Court
did not interfere on account of the individuals concerned, but for
the breach of the public peace.
Grose, J.,' agreed that those cases applied in principle to the
present, and that it was best to adhere to the established rule.
Rule discharged.
PEOPLE V. MARTIN.
Supreme Court of California, i 894.
102 California, 558.
Garoutte, ]} The appellant was convicted of obtaining
money and other personal property from one Sarah E. Leonard by
false and fraudulent pretenses. The information is laid under sec-
tion 532 of the Penal Code, and the false pretenses upon which it
is based consisted in the representations to said Leonard by the
defendant that a judgment in a large sum of money had been
obtained against her in the State of New York, and that her prop-
erty would be seized and sold to satisfy such judgment. The
information further states that said Leonard beUeved such state-
ments, and, so believing, and in order to avoid the application of
her property to the satisfaction of such judgment, she was induced
to, and did, transfer and deliver said property to defendant.
The information contained various allegations other than
those just noticed, and a demurrer was offered thereto upon
various grounds ; but we think the information well drawn, and
our consideration of the alleged defects therein will be limited to
the contention of appellant that the allegations we have in sub-
stance quoted therefrom constitute a bar to the prosecution of the
accused. Possibly the State might be barred from conducting a
1 BuLLER, J. , was sitting for the Lord Chancellor.
" Arguments of counsel and part of the opinion relating to another point
are omitted.
Cases on Criminal Law. 99
criminal prosecution by reasons of the acts of its duly constituted
officers representing the State in such matters ; but it is a novel
proposition that the acts and conduct of a private individual, even
though such individual be what is termed in law the prosecuting
witness, could, under any imaginable circumstances, bar the State
from the prosecution of a criminal. Appellant states her position
as follows :
" If, at the time that Sarah E. Leonard placed her property in
the possession of the defendant, she believed that there was a
valid and existing judgment for seventeen thousand dollars or
eighteen thousand dollars against her in the State of New York,
and she placed her property out of her hands to avoid its being
applied towards the satisfaction of such judgment, her intentions
were dishonest, and she was herself guilty of a criminal offense,
and became particeps criminis,"
The case of McCord v. People, 46 N. Y., 472, appears to sup-
port the doctrine insisted upon by appellant, but the great weight
of authority is to the contrary. It is said by the Court in Com-
monwealth V. Morrill, 8 Cush., 571 : " Supposing that to be other-
wise, and it should appear that Lynch (the party defrauded) had
also violated the statute, that would not justify the defendants ; if
the other party has also subjected himself to a prosecution for a
like offense, he also may be punished. This would be much better
than that both should escape punishment because each deserved it
equally." The doctrine of the foregoing case is approved by Mr.
Bishop in his work on Criminal Law, section 469, eighth edition.
The principle is also declared in the same work at sections 256
and 257. See, also. In re Cummins, 16 Col., 451, 25 Am. St.
Rep., 291. From any aspect of the case the contention has no
. sound support. If the party defrauded is also guilty of a viola-
tion of the law he, too, should be prosecuted, rather than his
offense should serve as a shield to the other's crime. The offense
is committed against the public, and not against the individual.
The guilty party is prosecuted in the interest of the people of the
State, and not in the interest of the party defrauded of his prop-
erty. There is no principle of law that will bar the State from prose-
cuting a criminal because some other person is a particeps criminis.
But, viewing the facts of this case in the light of the indictment,
the defrauded party committed no offense whatever. How could
loo Cases on. Criminal Law.
she possibly do so, when the pretenses were all false, and the
whole thing was but a scheme of lying and deceit? If such be a
crime, she transferred no property to evade its application upon a
money judgment which stood against her, for there was no such
judgment. Her intention to make a transfer for that purpose
avails nothing, for a person's intentions alone violate no law.
We have examined the additional assignments of error based
upon the rulings of the Court as to the admission and rejection of
evidence, and hold none of them to be well taken.
For the foregoing reasons, it is ordered that the judgment
and order be affirmed.
Harrison, J., McFarland, J., De Haven, J., and Van
Fleet, J., concurred.
Rehearing denied}
EFFECT OF CONSENT, ETC. {Continued.)
{e) Condonation of the Person Injured.
ROBERTS' CASE.
Select Pleas of the Crown, Sel. Soc. Pl. tj.
Cornish Eyre, 1201.
Malcot Crawe appeals Robert, Godfrey's son, of rape. He
comes and defends. It is testified that he thus raped her and
that she was seen bleeding. By leave of the justices they made
concord on the terms of his espousing her.
WILLIAMS z;. STATE.
Supreme Court of Georgia, 1898.
105 Georgia. 606.
Lumpkin, P. J. An indictment against G. W. M. Williams^
found by the grand jury of Screven county and transferred for
^Accord : Cunningham v. St., 61 N. J. L., 67 (1897). See also C. v.
Henry, 22 Pa., 253 (1853) ; Reg. v. Hudson, 8 Cox C. C, 305 (i860) ; C. v^
Shober, 3 Pa., Super.Ct., 554 (1897); Gilmore v. P., 87 111. App. 128 (1899);
Contra St. v. Crowley, 41 Wis., 271 (1876). — Ed.
Cases on Criminal Law. ioi
trial to the county court thereof, charged that the accused " did
falsely and fraudulently represent to J. C. White that he, the said
Williams, had purchased the Cuyler & Woodburn R. R. for the
sum of twenty-seven thousand dollars, and that he had raised all
of the purchase-price except one hundred dollars, and was then
on his way to Savannah to pay the purchase-money. By these
false and fraudulent representations the said G. W. M. Williams
fraudulently induced the said J. C. White to lend him, the said
G. W. M. Williams, the sum of one hundred dollars, which he
promised to pay back within three days from the date of the loan.
These representations, made as aforesaid, were all false and
fraudulent, and were made by the said Williams for the purpose
of defrauding the said White, and did in point of fact defraud the
said White, contrary to the laws of the said State, the good order,
peace and dignity thereof" At the trial, the State introduced
testimony substantiating all the material allegations of the indict-
ment. It distinctly appeared that in the conversation between
the accused and White which resulted in the former's procuring
tlie loan, he claimed to be the owner of the railroad in question.
For instance, he used the expression, " I don't want to encumber
my road," and other language indicating a purpose on his part to
create the impression that the railroad was his property. It was
further shown by the State that White was actually defrauded of
^loo, and that Williams did not repay the loan as he had agreed
to do. Evidence in behalf of the accused tended to show the
following : After Williams had been arrested upon a warrant
charging him with being a cheat and swindler, and before he was
indicted, he made a settlement with White by delivering to him
the promissory note of E. E. Wood & Co. for $ioo, which White
accepted in full satisfaction of his demand against Williams, and
afterwards sold for ;^90. There was a verdict of guilty in the
county court, and by his petition for certiorari Williams alleged
error as follows :
Second,' the judge erroneously charged that "a settlement
of the debt by White after the warrant had been sworn out, and
the defendant was under arrest or under bond, would be no bar to
the prosecution."
1 Only so much of the opinion as relates to condonation is printed.
102 Cases on Criminal Law.
We are also of the opinion that the second charge excepted
to was free from error. That a fraud was perpetrated upon White
plainly appeared. As a result of this fraud he was deprived of
the possession and use of his money, and it is apparent from the
evidence as a whole that there was a criminal intent on the part of
Williams not to return the money at all. That he was sub-
sequently forced to make restitution, which, as will have been
seen, was only partial, did not relieve him of the consequences of
his violation of the criminal statute, which was complete before
his arrest. As well might it be said that one guilty of a larceny
could escape prosecution by returning the stolen goods after being
arrested for the offense.
Judgment affirmed. All the Justices concurring.'
PEOPLE V. DALRYMPLE.
Supreme Court of Michigan, 1885.
55 Michigan, 519.
Exceptions before judgment from Berrien. (A. J. Smith, J.)
Nov. 19. — Jan. 13.
Adultery. Conviction set aside.
Attorney General Van Riper for the People.
Clapp & Bridgman for respondent.
CooLEY, C. J. The Attorney General very properly declines
to support the conviction in this case.
The prosecution was for adultery, and could only have been
instituted on the complaint of respondent's wife. How. Stat.,
§ 9279. The wife made complaint, but afterwards filed a paper in
court stating that she was overpersuaded to make it ; that she
would not have made it had she not been urged to do so ; that she
made it against her own feelings and wishes ; " that she has three
little boys of whom the oldest is only seven years of age, and that
1 Accord: Rape, C. v. Slattery, 147 Mass., 423 (1888) ; forgery, St. v.
Tull, 119 Mo., 421 (1894); seduction. Barker t/. C, 90 Va., 820 (1894);
false pretense, C. v. Brown, 167 Mass., 144 (1896); embezzlement. Dean 7/.
St., 147 Ind., 215 (1897). See also, St. v. Frisch, 45 La. Ann., 1283 (1893) ;
May 2/. St., IIS Ala., 14 (1896).— Ed.
Cases on Criminal Law. ioj,
for the sake of her children and her own peace and happiness she
most respectfully asks that Madison Dalrymple may be discharged
and that said cause may be discontinued." Notwithstanding this
request the prosecuting attorney pressed the case to a conviction.
Perhaps the letter of the statute was not disregarded in this
action, but its spirit was. The conviction must be set aside, and
the respondent discharged.
The other Justices concurred.'
ROHRHEIMER et al., v. WINTERS.
Supreme Court of Pennsylvania, 1889.
126 Pennsylvania, 253.
Per Curiam.^ An examination of the articles of agreement in
this case shows that the money to be paid by Shloss was to be paid
"in full satisfaction for the lying-in expenses, maintenance, education
and bringing up " of the plaintiffs child, of which the said Shloss was
the putative and self-acknowledged father. As this was a perfectly
legitimate and entirely proper purpose to be accomplished by the
agreement in suit, the contract ought to be enforced unless there is
some fatal legal objection to its validity. The only objection
alleged against it is the fact that the agreement discloses on its
face that it was given to stifle a criminal prosecution for fornica-
tion and bastardy.
It is true that the plaintiff did release to Shloss all civil and
criminal actions, demands and proceedings, which she might have
against him, and from this it may be inferred that one of the
motives which animated Shloss in making the agreement, might
have been the expectation of escaping a criminal prosecution.
But it is also true that ever since the year 18 19, the public policy
of this commonwealth as indicated by its public laws has not only
permitted but favored the settlement of just such cases as this, by
iln St. V. Smith, 108 Iowa, 440(1899), under a similar statute, it was
held that a husband does not by remarrying his first wife after being divorced
from her, with knowledge of adultery committed by her during the former
marriage, condone the offense so as to bar a criminal prosecution against her
partner in adultery. — Ed.
^ The opinion only is printed.
104 Cases on Criminal Law.
the voluntary agreement of the parties. We have several times
held that contracts between the reputed father and mother of the
child, for the settlement of claims founded upon fornication and
bastardy, are not illegal and will be enforced. A noted instance of
this kind was the case of Maurer v. Mitchell, 9 W. & S., 69, in which
Chief Justice Gibson said, speaking of the act of 18 19: "Thus
the offence, like assault and battery with which it was associated
in that statute, became little more than a private wrong ; and
when the legislature authorized the parties to treat it as such
between themselves, the contract certainly became legal so far as
they were individually concerned." This act certainly continued
in force until i860, and, as the criminal code enacted in that year
also sanctioned the settlement of misdemeanors, an unbroken
practice has prevailed in all parts of the State, for a great many
years, of settling cases of this kind by the voluntary agreement of
the parties. In view of this long continued practice and of the
judicial and legislative sanction which it has received, and in view
also of the fact that the chief subject matter of the contract is the
support of the child, we cannot say that such contracts are opposed
to the public policy of the State. As there is no other reason for
refusing the enforcement of this particular agreement we think it
should prevail.
Judgment affirmed.
Cases on Criminal Law. 105
EFFECT OF CONSENT, ETC. {Continued:)
(/) Condonation of the State.
" If any felons will confess their crimes and accuse others
and become approvers, let them be put out of penance, and let
their confessions be presently received and enrolled by the coroner,
and from that day forward let them have of the sheriffs three half
pence a day for their support." — Britton, 12.
COMMONWEALTH v. ST. JOHN.
Supreme Judicial Court of Massachusetts, 1899.
173 Massachttsetts, 566.
Morton, J.' The decisive question in each case is the same
and the cases may therefore properly be considered together.
The question is whether the immunity that was promised to the
defendants by the city marshal and by Boyle, the chief detective of
the police department of Springfield, can be pleaded in bar of the
indictment against them. We think that it cannot. The immunity
and protection which may be promised from the consequences of
crime on condition of a full disclosure and readiness to testify are
not a matter of right, but rest in the last resort on the sound
judicial discretion of the court having final jurisdiction to sentence,
and cannot therefore be pleaded in bar. Wight v. Rindskopf, 43
Wis., 344 ; State v. Moody, 69 N. C, 529 ; State v. Graham, 12
Vroom, IS; Rex v. Rudd, Cowp., 331; Whart. Crim. Ev. §§
439, 443 ; 3 Russ. Crimes, (9th Am. ed.) 599.
When such promises are made by the public prosecutor or
with his authority, the court will see that due regard is paid to
them, and that the public faith which has been pledged by him is
duly kept. The prosecuting officer has also the power to enter a
nolle prosequi. It appears in each case that neither the city mar-
shal nor Boyle had any authority from the District Attorney to
1 The opinion only is printed.
io6 Cases on Criminal Law.
make the promises or hold out the inducements which they did.
There is nothing in either bill of exceptions tending to show that
the District Attorney had anything to do with the prosecution in
the police court. Neither of the defendants appeared before the
grand jury, although they were at the court house from day to day
when the grand jury was in session, ready to testify, relying on
the promises of immunity made by the city marshal and by Boyle.
And there is nothing tending to show that there was any expecta-
tion or understanding on the part of the District Attorney that
either was to testify as a government witness in the Superior
Court, and neither did so testify. If an appeal had been made to
the clemency of the court, it would no doubt have been competent
for the court to take into consideration the inducements which had
been held out and the promises that had been made, if any, by the
city marshal and by Boyle. But what was done was to plead the
promises and inducements in bar. A question of law was thus
presented, and we think that the ruling of the court was clearly
right. Exceptions overruled^
EFFECT OF CONSENT, ETC. {Continued:)
(£■) Custom.
LAWRENCE v. STATE.
Court of Appeals of Texas,- 1886.
20 Texas Appeals, 536.
The indictment in this case charged the appellant with the
theft of two hogs, of the aggregate value of ^40, the property of
B. C. Hutchins, in Gonzales county, Texas, on the ist day of
Where it is provided by statute that no case shall be dismissed without
permission of the presiding judge, an agreement of the district attorney to
dismiss a case, provided the defendant will become a witness for the State,
is not binding on the State if the judge does not consent thereto. See
Tullis V. St., 52 S. W. (Tex.) 83 (1899).
By statutes of limitation many States prescribe that prosecutions must be
brought within a specified time after the commission of the offense. — Ed.
Cases ON Criminal Law. 107
December, 1883, His conviction, and the penalty assessed, are
expressed in the verdict, to which allusion is made in the opinion
as follows :
" We, the jury, find the defendant guilty of theft of property
of value of less than ;^20, and assess his punishment at six months
confinement in the county jail, and ^400 fine."^
White, Presiding Judge. One theory of the defense in this
case was that appellant was the hired hand of his brother. His
brother, who was a witness, testified to that fact. After he had so
testified, defendant further proposed to prove by him that he had
instructed his brother, the defendant, to kill all unmarked grown
hogs ; and further, to prove by the witness that it was a general
custom of the country that any one had a right to kill all unmarked
hogs over twelve months old running on the range ; and the court
refused to admit such evidence, and defendant .served a bill of
exceptions to the ruling and claims the ruling as error. Not only
so, but upon this point he claims that additional error was com-
mitted by the court in refusing a special requested instruction as
follows : " That the statutes of this State require that all hogs,
sheep and goats shall be marked with the ear-mark of the owner,
on or before they are six months old, and if the jury find from the
evidence that the hogs in controversy were over six months old,
and were unmarked, and that defendant killed them not knowing
them to be the property of Hutchins, then the defendant would
not be guilty of theft, and the jury should acquit."
In order to constitute theft it is not essential that the thief
should know who is the owner of the property he has stolen, and
such a doctrine was not intended to be announced as a general
rule under the facts upon which the case of Boyd v. The State, 18
Texas Ct. App., 339, was decided. On the contrary, theft, or "a
fraudulent taking of the property of another, embraces the idea
that the taker knew that it was not his own, and also that it was
done to deprive the true owner of it," Smith v. The State, 42
Texas, 444, whether he knew who the true owner was or not.
No error was committed in refusing to admit proof that it was
a general custom of the country that any one had the right to kill
all unmarked hogs over twelve months old, running on the range.
' The evidence in this case is omitted
io8 Cases on Criminal Law.
It is true that the law requires that the owner shall place his ear-
mark upon hogs, sheep and goats, on or before they are six months
old. Rev. Stats., Art. 4558, but a failure to do so does not affect,
much less destroy, the owner's right to his property. His recorded
mark is not even required as the best evidence of ownership, as is
the case with brands. Rev. Stats., Art. 4561 ; Dixon v. The
State, 19 Texas, 134; Johnson v. The State, l Texas Ct. App.,
333 ; Love v. The State, 15 Texas Ct. App., 563 ; Dreyer v. The
State, II Texas Ct. App., 632. To fraudulently take such prop-
erty when unmarked is as much theft as if it had been marked.
This is the rule of the law, and ignorance of the law is no excuse.
Penal Code, Art. 14. A rule of law can never be subverted by
local custom. To sanction the doctrine that it could would be to
unsettle the law, would open for discussion and neighborhood
proof not the facts but the law, and allow such neighborhood the
right to claim a distinct law of its own, thereby destroying the
beauty of the law which consists in the uniformity of its action
throughout the land." Lockhart v. Dewees, i Texas, 535 ; Mc-
Kinney v. Fort, 10 Texas, 220; White & Wilson's Ct. App. Civil
Cases, §§272, 353.696.
It would seem that the case of Dibbs v. The State, 43 Texas,
650, announces a different doctrine, and in so far as it does it is
hereby overruled. It is folly to talk about an individual gifted
with enough intelligence to render him responsible for his acts hon-
estly believing that he has the right to claim and appropriate all
the unmarked yearlings, sheep, hogs and goats in Texas that are a
year old. Such a custom would be a monstrosity which the law
would never tolerate. It was not error to refuse defendant's special
requested instruction as above quoted.
One of the instructions given by the court to the jury was as
follows : " The jury are further instructed that if they believe from
the evidence that the defendant took the hogs charged in the in-
dictment, yet that he so took them with an honest belief, although
he may have been mistaken in such belief, that he had the right or
the authority to do so, or if the evidence on this point is such as
to raise in your minds a reasonable doubt as to whether the defend-
ant did believe he had the right to take such hogs, then in such
case you will give him the benefit of such doubt and acquit him."
The instruction fully and sufficiently covered the important
Cases on Criminal Law. 109
material issues in the case with reference to which the appellant is
here complaining. If he wished more specific instructions upon
these points he should have asked them, and presented them in
such shape as that the court could give them. Whilst a court
may qualify or modify an instruction which is asked, so as to make
it present the law as the court conceives the law to be, yet the
court is not bound to qualify or modify an illegal or erroneous in-
struction, but may refuse it outright. We are of opinion that the
verdict of the jury is sufficiently definite and specific under our
present statute. Penal Code, Art., 748. There is some conflict
in the evidence but if the testimony of the State's witnesses is be-
lieved, the proof is amply sufficient to support the verdict and
judgment, and the judgment is affirmed. Affirmed}
SECTION X.
EFFECT OF COERCION.
(a) Coverture.
If a ceorl steal a chattel and bear it into his dwelling, and it
be attached therein, then shall he be guilty for his part, without
his wife, for she must obey her lord. If she dare to declare by
oath that she tasted not of the stolen property, let her take her
third part. Laws of King Inc. , Cap. 57.
A wife, however, who is the spouse of a thief, shall not be
liable for the act of the man, because she ought not to accuse her
husband nor to disclose his theft or felony, since she has not any
power over herself, but her husband has. She ought not, how-
ever, to consent to the felony of her husband, nor to be his con-
federate. * * * It is not, therefore, in every case that the woman
is to be set free, on account of her counsel, aid, or consent, accord-
ing as they have been accomplices in the crime, they shall be par-
takers in the punishment. Bracton, Book j, Chap, 32.
1 Accord: On indictment for larceny, C. v. Doane, i Cush., 5 (1848) ;
riot, Bankus v. St. 4 Ind., 114 (1853) ; indecent exposure, Reg v. Reed, 12
Cox C. C. I (1871); Hendry v. St, 39 Fla., 235 (1897); embezzlement,
BollnT/. St. 51 Neb., 581 (1897).— Ed.
no Cases on Criminal Law.
SARAH CONNOLLY'S CASE.
Durham Assizes, 1829.
2 Lewin, 229.
The prisoner was indicted for uttering base coin.
The evidence was that she had gone from house to house
uttering base coin, and that her husband accompanied her to the
door, but did not go in.
Bayley, J. directed the jury to infer that she was acting under
the coercion of her husband, and to find her not guilty.
REX V. HUGHES.
Lancaster Assizes, 18 13.
2 Lewin, 229.
Martha Hughes, the wife of Patrick Hughes, was indicted
for forging and uttering three £2 Bank of England notes.
James Piatt proved that he went to the shop of the prisoner's
husband, in consequence of a conversation which he had had some
time before with the husband. The husband was not present. The
prisoner beckoned him to go into an inner room, into which she
followed him, when he told her what her husband had said to him.
They then agreed about the business, and the witness bought of
the prisoner three £2 notes at ;^i 4s. each.
The witness paid her four £\ notes and was to receive Ss. in
change. When he was putting the notes into his pocketbook, and
before he received the change, the husband put his head into the
room and looked in, but did not come in or interfere in the busi-
ness further than by saying, " Get on with you ! " When the wit-
ness and the prisoner returned into the shop the husband was
there and the prisoner gave him the change, and both the prisoner
and the husband cautioned him to be careful.
On these circumstances being proved. Cross, for the prisoner,
objected that they clearly established that she acted under the
coercion of her husband. Supposing both husband and wife on
their trial, this evidence would be sufficient to convict him ; and he
Cases on Criminal Law. hi
submitted that, if so, she must in this case be acquitted. He cited
2 East's P. C, 259 : " If a wife be guilty of larceny in company
with her husband, both of them may be indicted, and if the
husband be convicted the wife shall be acquitted, i Hale 46 ;
Kelynge, 37. " But if the husband be acquitted, and it appear that
the felony were by her own voluntary act (by which must be under-
stood that her husband, if present, had no knowledge of or par-
ticipation in the fact), she may, upon the same indictment, be
convicted, for the charge is joint and several. The acquittal or
conviction, therefore, of the husband, regulates that of the wife.
Here the husband might have been convicted.
Thompson, B. (stopping Park and Rain) : " I am very clear as
to the law on this point.
" The law, out of tenderness to the wife, if a felony be com-
mitted in the presence of the husband, raises a presumption prima
facie, and prima facie only (as is strongly laid down by Lord Hale),
that it was done under his coercion. But it is absolutely necessary
that the husband should be actually present and taking a part in
the transaction.
" Here it is entirely the act of the wife. It is, indeed, in con-
sequence of a communication previously with the husband, that
the witness applies to the wife, but she is ready to deal, and has on
her person the articles which she delivers to the witness.
"There was a putting off before the husband came; and it
was sufficient if, before that time, she did that which was necessary
to complete the crime. The coercion must be at the time of the
act done, and then the law, out of tenderness, refers it, prima facie,
to his coercion ; but when it has been completed in his absence,
no subsequent act of his (although it might possibly make him an
accessory to the felony of his wife) can be referred to what was
done in his absence."
Objection overruled.
" When coercion is once established, it should shield the wife — at least
until it appears that she has been relieved from its influence — and we do not
think that after being coerced into giving assistance to her husband, that
simply because she may be the most active in consummating the offence, that
this should, as matter of law, make her guilty. On the contrary, the question
should still depend on the cause of her increased activity, and not upon the
fact of such activity. The presence and constraint of her husband may still
be the cause and not her own wickedness.'! Simpson, C. J., in St. v. Hous-
ton, 29 S. C, 108 (1888).
112 Cases on Criminal Law.
SEILER V. PEOPLE.
Court of Appeals of New York, 1879,
77 New York, 41 1.
FoLGER, J.^ The mostthatcan be claimed forthe evidence in this
case is that the plaintiff in error was in company with the man Brown,
just before and just after the larcenous act. She was not near to
him when it was done. He was 200 feet or more away. It may
be that his eye was upon her, and that she knew it ; no more than
that.
It was not error for the court, therefore, to state to the jury
the distance off which Brown was shown to be ; especially as it
was stated, on which to remark to them, that it was for them to say
whether that fact did not rebut the presumption that she was
coerced by him, and to find whether she was in his presence.
The request to charge, that if the four conspired to steal, she
must be presumed to be coerced by him, if when she entered the
store he was at the entrance, was well denied. His command or
procurement would not excuse her. The theft was not done
while he was at the entrance. He had passed on, before that. It
is the presence of the husband at the thieving act, which raises the
presumption.
The court was right in telling the jury that the questions
were : Whether Brown was her husband ; and was present when
the theft was done. It was right in refusing to charge, that the
facts were proven from which coercion was to be presumed ; for
the presence of Brown at the act was not proven. There was no
error on the trial.
The judgment should be affirmed.
All concur. Judgment affirmed. ^
^Part of this case is omitted.
^Under a statute allowing, but not compelling a wife to testify in a crim-
inal case in which her husband is defendant if, in giving her testimony, her
husband being present, she commits perjury, the presumption of coercion
does not arise. C. v. Moore, 162 Mass., 441 (1894); see also Smith v.
Meyers, 54 Neb., i (1898); nor does the presumption arise on an indictment
for keeping a gaming house. Rex v. Dixon, 10 Mod, 335 (1715); or a baiii^y
house, Reg. v. Williams, 10 Mod., 63 (1711); even though her husband
resided in the house and hired, furnished, and provided for it. C. t/.
Cheyney, 114 Mass., 281 (1873). — Ed.
Cases on Criminal Law. i ij
Gantt, p. J., in St. v. Ma Foo, i lo Mo. 7, (1891) : "Learned
counsel for defendant desire us to ingraft an additional modifica-
tion on this rule of evidence, and require the State to go further
and prove that the husband not only was not the inciter or re-
sponsible criminal agent in the commission of the crime, but that
he actually disapproved it, and, in the absence of evidence of his
disapproval, the wife must be acquitted. This is not the law.
There is little in the present organization of society upon which
the prima facie presumption itself can stand, and certainly nothing
calling for any extension of the presumption."
" Before Somerville's case, 26 Eliz., and Somerset's case, A. D. 161 5, I
find no exception to the general rule that the coercion of the husband excuses
the act of the wife. (See 27 Ass. 40, Stamf. P. C, 26, 27, 142 ; Poulton de
pace Regis., 130 Br. Ab. Coron.^ 108 ; Fitz. Ab. Coron., 130, 180, 199.) But
after these cases I find the following exceptions in the books : Bac. Max., 57,
except treason only, Dalton, c. 147, treason and murder, citing for latter
Mar. Lect. 12 (which I conceive refers to the reading of Marrow, a Master in
Chancery, in the time of Henry VII. See Willes v. Bridger, 2 B. and A. 282).
I Hale, P. C. , pp. 45, 47, treason, murder and homicide; and p. 434, trea-
son, murder and manslaughter; Kel. 31, an obiter dictum, murder only ;
Hawk., b. I, c. l, s; 11, treason, murder and robbery; Blac. Com., vol. i,
p. 444, treason and murder ; vol. iv, p. 29, treason and mala in se, as murder
and the like. Hale therefrom alone excepts manslaughter, and Hawkins
introduces robbery, without any authority for so doing; and, on the contrary,
in R. V. Cruse, 8 C. and P. 545, a case is cited, where Burrough, J. , held that
the rule extended to robbery." It seems long to have been considered that
the mere presence of the husband was a coercion (see 4 Blac Com., 28), and
it was so contended "in R. v. Cruse; and Bac. Max. 56, expressly states that
a wife can neither be principal nor accessory by joining with her husband in
a felony, because the law intends her to have no will ; and in the next page
he says: " If husband and wife join in committing treason, the necessity of
obedience doth not excuse the wife's offense, as it does in felony." * * *
Dalton cites the exception from Bacon without the rule, and Hale follows
Dalton, and the other writers follow Hale ; and it seems by no means improb-
able that the exceptions of treason and murder, which seem to have sprung
from Somerville' s and Somerset' s cases, and which were probably exceptions
to the rule as stated by Bacon, have been continued by writers without advert-
ing to their origin, or observing that the presence of the husband is no longer
considered an absolute excuse, but only affords a prima facie presumption
that the wife acted by his coercion." Russell on Crimes (^International
Edition), p. 146. Note by Greaves.
114 Cases on Criminal Law.
EFFECT OF COERCION {Continued).
(3) Command.
MEMORANDUM, 1660.
Kelyng, 13.
Upon the trial of one Axtell, a soldier who commanded the
guards at the King's Tryal, and at his murder ; he justified that
all he did was as a soldier, by the command of his superior
officer, whom he must obey or die. It was resolved that was no
excuse, for his superior was a traitor, and all that joined him
in that act were traitors, and did by that approve the treason ;
and where the command is traitorous, then the obedience to that
command is also traitorous.
RIGGS V. STATE.
Supreme Court of Tennessee, 1866.
3 Coldwell, 85.
Theplaintififinerror, was convicted at the August Term, i866,
of murder in the second degree, and sentenced to fifteen years
imprisonment in the penitentiary ; from which he appealed. Judge
James P. Swan, presiding.
R. M. Barton and McFarland, for the plaintiff in error.
Trowbridge and Thos. H. Coldwell, Attorney General, for the
State.
Shackelford, J., delivered the opinion of the Court.
The plaintiff in error was indicted in the Circuit Court of Jef-
ferson County, for the killing of Captain Thornhill. A change of
venue was had to the County of Grainger. At August Term, 1866,
of the Circuit Court of Grainger County, he was convicted by a
jury, of murder in the second degree, and sentenced to fifteen
years imprisonment in the penitentiary.
A new trial was moved for, which was overruled, and an
appeal taken to this Court.
The Court, among other things not excepted to, charged the
jury in substance as follows : " A soldier in the service of the
United States is bound to obey all lawful orders of his superior
Cases on Criminal Law. i i 5
officers, or officers over him, and all he may do in obeying such
lawful orders, constitutes no offense as to him. But an order,
illegal in itself, and not justified by the rules and usages of war, or
in its substance being clearly illegal, so that a man of ordinary
sense and understanding would know, as soon as he heard the
order read or given, that such order was illegal, would afford a
private no protection for a crime committed under such order,
provided the act with which he may be charged, has all the ingre-
dients in it which may be necessary to constitute the same a crime
in law. Any order given by an officer to his private, which does
not expressly and clearly show on its face, or in the body thereof,
its own illegality, the soldier would be bound to obey, and such
order would be a protection to him. No person in the military
service has any right to commit a crime in law, contrary to the
rules and usages of war, and outside of the purposes thereof; and
the officers are all amenable for all crimes thus committed, and the
privates likewise are answerable to the law for crimes committed
in obeying all orders illegal on their face and in their substance,
when such illegality appears at once to a common mind, on hear-
ing them read or given." We think there is no error in this charge.
It is a well-settled principle, a soldier is not bound to obey an
illegal order. If he does, and commits an offense, it is no justifica-
tion to him, and he is liable to be proceeded against and punished.
This principle was settled in the Supreme Court of the United
States, in the case of Mitchell v. Harmon, 13 Howard, 129, in
which it was held a military officer cannot rely on an apparently
unlawful order of his superior, as a justification.
The same principle was recognized and settled in the Court of
King's Bench, reported in i Cowp., 180. In this case, a captain
in the English navy, by orders of the British admiral, pulled down
the houses of some Suttlers on the coast of Nova Scotia, who were
supplying the sailors with spirituous liquors, and the health of the
sailors was thereby much injured. The motive was a laudable one,
and done for the public service. The Courts say, it was an invasion
of the rights of private property, without the authority of law, and
the officer, who executed the order, was held liable. This being
the rule in civil causes, the principle would be more strictly applied
in criminal ones. No order, if any was given, could justify the
killing of Captain Thornhill, and the parties who did the act are
ii6 Cases on Criminal Law.
amenable to the criminal law. There being no error in the charge
of the Court, the question arises : Do the facts in the record sus-
tain the verdict of the jury ? And under the rulings of this Court,
it is made our duty, in criminal causes, to examine the proof, and
see if it warrants the conviction.^
The proof does not satisfy us the prisoner aided or abetted in
the unlawful act of killing. A private soldier when detailed by his
Superior officer has no discretion. By the rules of war he is bound
to obey the orders of those in command. When he enters the
service, unconditional submission to the lawful orders of his superior
officers is a duty imposed upon him by his oath and the articles of
war. The principle of law, " when men are assembled for an
illegal purpose, and the commission of an offense by any one
of the party is the act of the whole," is not applicable to this
Case. The plaintiff in error being a private soldier, being detailed,
was bound to obey the lawful order. The going to Richard
Thornhill's without a knowledge of the purpose for which the force
was detailed, was not an illegal act ; he had no right to inquire of
the officer the object and purpose of the detail, or what he had in
view ; and if he was present, unless he participated in the killing-
by firing, or aided and abetted in the act of killing, he would not
be criminally responsible. It is stated as a principle of law, in i
Hale, Pleas of the Crown, 444, and which we recognize arid approver
"Although if many come upon an unlawful design, and one of the
company kill the adverse party, in pursuance of that design, all
are principals ; yet if many be together upon a lawful account, and
one of the company kill another of an adverse party, without any
particular ?ibetment of the rest to this fact of homicide, they are
not all guilty that are of the company, but only those that gave
the stroke, or actually abetted them to do it." We forbear to
comment further upon the testimony, as the case will undergo
another investigation before a jury. We are not satisfied from the
proofs in this record, with the verdict of the jury.
The judgment will be reversed, and a new trial awarded. '
^ Part of the opinion is omitted.
'Accord. U. S. v. Jones, 3 Wash. C. C, 209 (1813) ; In re Fair, 100
Fed. R., 149 (1900).
See for command of master, Sanders v. St, 26 S. W. (Tex.), 62 (1894);.
Parent, P. v. Richmond, 29 Cal., 414 (1866). Compare Reg. v. Boober, 4
Cox C. C, 272 (1850).— Ed
Cases on Criminal Law. i 17
EFFECT OF COERCION. {Continued.)
(c) Threats.
UNITED STATES v. VIGOL.
United States Circuit Court, District of Pa, 1795.
2 Dallas, 346.
Indictment for high treason in levying war against the United
States. The prisoner was one of the most active of the insurgents
in the western counties of Pennsylvania, and had accompanied the
armed party who attacked the house of the excise officer (Reigan's)
in Westmoreland, with guns, drums, &c., insisted upon his surren-
dering his official papers, and extorted an oath from him that he
would never act again in the execution of the excise law. The
same party then proceeded to the house of Wells, the, excise officer
in Fayette County, swearing that the excise law should never be
carried into effect, and that they would destroy Wells and his house.
On their arrival Wells had fled and concealed himself, whereupon
they ransacked the house, burned it, with all its contents, including
the public books and papers ; and afterwards discovering Wells,
seized, imprisoned and compelled him to swear that he would no
longer act as excise officer. Witnesses were Hkewise examined to
establish that the general combination and scope of the insurrection
were to prevent the execution of the excise law by force ; and in
the course of the evidence, the duress of the marshal of the dis-
trict, the assembling at Couche's, the burning of General Neville's
house, &c., were prominent features.
Patterson, Justice. ' The counsel, for the prisoner have
endeavored, in the course of a faithful discharge of their duty, to
extract from the witnesses some testimony which might justify a
defence upon the ground of duress and terror. But in this they
have failed, for the whole scene exhibits a disgraceful unanimity; and
with regard to the prisoner, he can only be distinguished for a guilty
pre-eminence in zeal and activity. It may not, however, be useless
on this occasion, to observe that the fear that the law recognizes as
^ Part of this case is omitted.
ii8 Cases on Criminal Law.
an excuse for the perpetration of an offense must proceed from an
immediate and actual danger, threatening the very life of the party.
The apprehension of any loss of property by waste or fire, or even
an apprehension of a slight or remote injury to the person, furnish
no excuse. If, indeed, such circumstances could avail, it would be
in the power of every crafty leader of tumults and rebellion to
indemnify his followers by uttering previous menaces ; an avenue
would be forever open for the escape of unsuccessful guilt, and
the whole fabric of society must inevitably be laid prostrate.
Verdict, Guilty}
BAIN V. STATE.
Supreme Court of Mississippi, 1890.
67 Mississippi, 557.
From the Circuit Court of Attala county.
Hon. C. H. Campbell, Judge.
The case is stated in the opinion.
Allen &• McCool, for appellant.
It cannot be the law that nothing is " duress " but a fear of
being killed or receiving some serious bodily harm while testifying
in court. If so, there can be no legal duress to protect a witness
whose evidence is untrue, since there is not an example in all juris-
prudence to support such a view. Antecedent circumstances were
preying on the mind of the defendant at the time he testified. His
calamity placed him in agonizing fear, and hence his clean breast
for the State. An improper influence may be exerted in court as
well as out of it. Serpentine z/. The State, i How. (Miss.), 256.
Slight expressions engendering hope or fear, will avoid the false
oath. 37 Mis., 288 ; 4 Mich., 607.
The burden of showing duress rested on the defendant, and he
should have had liberty to explain by aliunde proof. 41 Am. Rep.,
296 ; 28 Min., 426; 9 Gray, 109 ; 15 lb., 495.
Improper influence once shown to exist is presumed to con-
tinue, unless lapse of time or other circumstances sufficient to
dispel the influence of hope or fear have intervened, and in such
1 Accord: Treason, Respublica v. M'Carty, 2 Dall., 86 (1781) ;
Mutiny, U. S. v. Haskell, 4 Wash. C. C, 402 (1823).— Ed.
Cases on Criminal Law. 119
case any subsequent confessions will be rejected unless they are
shown to be voluntary, i Greenleaf Ev., § 221 ; 37 Miss. 288;
44 lb., 333, 382 ; Roscoe, Crim. Ev. (7 ed.), 48.^
Cooper, J., delivered the opinion of the court.
The appellant has been indicted and convicted of the offense
of perjury. The sole defense attempted to be proved was that
appellant's life had been threatened by one Veto Dodd, unless he
should go into court and testify so as to criminate himself and
certain other persons who were suspected of having- murdered a
negro man and his wife, tenants upon the farm of Dodd. The
court below excluded the evidence tendered to show the threats
upon the ground that it was not proposed to be shown that the
threats were made at the instant of delivery of the testimony nor in
the presence of the court in which the appellant was testifying. This
ruling of the court is the foundation of the errors assigned, the
assignments of error other than the first presenting the same ques-
tion in different forms.
Counsel for appellant press upon our attention with apparent
confidence that numerous class of cases in which the credibility of
confessions or of testimony has been assailed and impeached by
the circumstances under which the confessing person or witness
spoke. We fail to perceive their application to the case at bar, in
which the single question is, whether a man may justify or excuse
deliberate perjury against the life and liberty of others on the
ground that he was coerced to the perjury by fear engendered by
the threats of others.
We are not aware that a similar question has ever been pre-
sented for decision.
We can conceive of cases in which an act, criminal in its
nature, may be committed by one under such circumstances of
coercion as to free him from criminality. The impelling danger,
however, should be present, imminent and impending, and not to
be avoided.
Such was not the character of the duress here, and the appel-
lant was not only possessed of the power and right of protecting
himself, but he also could have appealed to the law to shield him
from the threatened danger.
■■ Part of the argument of counsel is omitted.
120 Cases on Criminal Law.
If Dodd, by whom the threats were made, should attempt to
carry them into execution, the appellant might lawfully oppose
force to force, and if necessary might, in the defense of his person,
lawfully slay his assailant. But if appellant feared the superior
strength or courage of Dodd, he might have invoked the protec-
tion of the court.
The law has made ample provision for the protection of
persons and property under precisely the circumstances named by
appellant. By section 3126 of the code it is provided that,
" whenever complaint is made under oath by a credible person to
any justice of the peace that any person has threatened to commit
any offense punishable by the laws of this State against the person
or property of another, and such justice is satisfied that there is
good reason to fear the commission of such ofTense, he may issue
his warrant to arrest and bring the person complained of before
himself, or some other justice of the peace, and the justice of the
peace before whom such person may be brought shall examine
into said charge, and if there be just reason to apprehend that such
person will commit the offense, he shall be required by such justice
to enter into bond or recognizance in such sum, and with such
sureties, and for such time, not exceeding twelve months, as such
justice may prescribe, conditioned to keep the peace towards
the person against whom or whose property there is reason to fear
the offense may be comitted."
If default be made in giving the bond required by the justice,
it is provided by section 3 128 that the person so failing shall be by
the officer committed to jail until the bond be given, or until the
expiration of the time for which he was required to furnish such
security.
The social system would be subverted and there would be no
protection for persons or property if the fear of man, needlessly
and cravenly entertained, should be held to justify or excuse
breaches of the criminal laws of the State, and to excuse or justify
the crime of perjury.
The judgment is affirmed.
Cases on Criminal Law. i 2 1
ARP V. STATE.
Supreme Court of Alabama, 1892.
97 Alabama, 5.
Coleman, J. At the July Term, 1892, of the Circuit Court,
the defendant was convicted of murder in the first degree, and
sentenced to suffer death. ^
The testimony of the defendant and the evidence admitted as
confessions, showed that he took the Hfe of the deceased without
provocation on the part of the deceased, and when there was no
real or apparent necessity for the act so far as such necessity pro-
ceeded from the deceased. According, to his own statement, the
object to be accomphshed by taking the life of the deceased was
to prevent deceased from appearing as a witness against him, and
one Burkhalter and Leith, charged with retailing whiskey without
a license. The defendant's excuse for the homicide was that
Burkhalter and Leith threatened to take his life unless he killed
ie7is.
Ignorance of thelawis no excuse for the violation of it, and if a person
choose to run the risk of committing a felony, he or she must take
the consequences if it turn out that a felony has been committed.
Great stress is laid by those who hold that the conviction
should be quashed upon the circumstance that the crime of bigamy
is by the statute declared to be a felony and punishable with penal
servitude or imprisonment with or without hard labor for any term
not exceeding two years. If the crime had been declared to be a
misdemeanor punishable with fine or imprisonment, surely the
construction of the statute would have been, or ought to have
been the same. It may well be that the Legislature declared it to
be a felony to deter married persons from running the risk of
committing the crime of bigamy, and in order that a severe pun-
ishment might be inflicted in cases where there were no mitigating
circumstances. No doubt circumstances may and do affect the
sentence, even to the extent of the punishment being nominal, as it
was in the present case, but that is a very different thing from disre-
garding and contravening the plain words of the Act of Parliament.
The case is put by some of my learned Brothers of a married
man leaving his wife and going into a foreign country intending
to settle there, and it may be afterwards to send for his wife and
children, and the ship in which he goes is lost in a storm with, as
is supposed, all on board, and after the lapse of say a year, and no
tidings received of any one having been saved, the underwriters
pay the insurance on the ship, and the supposed widow gets probate
of her husband's will and marries and has children, and after the
lapse of several years the husband appears, it may be a few days
before seven years have expired, and the question is asked, would
it not be shocking that in such a case the wife could be found
guilty of bigamy?
My answer is that the Act of Parliament says in clear and
express words, for very good reasons as I have already pointed out,
that she is guilty of bigamy. The only shocking fact would be that
some one for some purpose of his own had instituted the prosecu-
tion. I need not say that no public prosecutor would ever think of
doing so, and the judge before whom the case came on for trial
would, as my brother Stephen did in the present case, pass a
19° Cases on Criminal Law.
nominal sentence of a day's imprisonment (which in effect is imme-
diate discharge) accompanied, if I were the judge, with a disallow-
ance of the costs of the prosecution. It may be said, but the
woman is put to some trouble and expense in appearing before
the magistrate, who would of course take nominal bail, and in
appearing to take her trial. Be it so, but such a case would be
very rare indeed. On the other hand, see what a door would be
opened to collusion and mischief if, in the vast number of cases
where men in humble life leave their wives and go abroad, it
would be a good defence for a woman to say and give proof, which
the jury beheved, that she had been informed by some person upon
whom she honestly thought she had reason to rely, and did
believe, that her husband was dead, whereas in fact she had been
imposed upon and her husband was alive.
What operates strongly on my mind is this, that if the Legis-
lature intended to prohibit a second marriage in the lifetime of a
former husband or wife, and to make it a crime, subject to the
proviso as to seven years, I do not believe that language more apt
or precise could be found to give effect to that intention than the
language contained in the 57th section of the Act in question. In
this view I am fortified by several sections of the same Act, where
the words "unlawfully" and "maliciously and unlawfully " are
used (as in s. 23), and by a comparison of them with the section in
question (s. 57), where no such words are to be found. I espe-
cially rely upon the 55th section by which it is enacted that
"whosoever shall unlawfully" (a word not used in s. 57) "take or
cause to be taken any unmarried girl being under the age of
sixteen years out of the possession of her father or mother or any
other person having the lawful care or charge of her, shall be
guilty of a misdemeanor." Fifteen out of sixteen judges held
in the case of Reg. v. Prince, Law Rep., 2 C. C. R., 1 54, that, not-
withstanding the use of the word " unlawfully " the fact of the
prisoner believing and having reason to believe that the girl was
over sixteen afforded no defence. This decision is approved of
upon the present occasion by five judges, making in all twenty
against the nine who are in favor of quashing the conviction. To
the twenty I may, I think, fairly add Tindal, C. J., in Reg. v.
Robins, i C. & K., 456, and Willes, J., in Reg. v. Mycock, 12
Cox C. C, 28.
Cases on Criminal Law. 191
I rely also very much upon the 5th section of the Act passed
in 1885 for the better protection of women and girls, 48 & 49
Vict. c. 69, by which it was enacted that " any person who unlaw-
fully, and carnally knows any girl above thirteen and under sixteen
years shall be guilty of a misdemeanor," but to that is added a
proviso that " it shall be a sufficient defence if it be made to appear
to the Court or j ury before whom the charge shall be brought
that the person charged had reasonable cause to believe and did
believe that the girl was of or above the age of sixteen." It is to
be observed that notwithstanding the word " unlawfully " appears
in this section it was considered necessary to add the proviso,
without which it would have been no defence that the accused had
reasonable cause to believe and did believe that the girl was of or
above the age of sixteen. Those who hold that the conviction in
the present case should be quashed really import into the 57th
section of the 24 & 25 Vict. c. 100, the proviso which is in the
5th section of the 48 & 49 Vict. c. 69, contrary, as it seems to me,
to the decision in Reg. v. Prince, Law Rep., 2 C. C. R., 154, and
to the hitherto undisputed canons for construing a statute.
It is said that an indictment for the offence of bigamy com-
mences by stating that the accused feloniously married, &c., and
consequently the principle of mens rea is applicable. To this I
answer that it is to the language of the Act of Parliament and
not to that of the indictment the Court has to look. I consider
the indictment would be perfectly good if it stated that the
accused, being married, married again in the lifetime of his or her
wife or husband contrary to the statute, and so was guilty of
felony.
I am very sorry we had not the advantage of having the case
argued by counsel on behalf of the Crown. My reason for abstain-
ing from commenting upon the cases cited by Mr. Henry in his
very able argument for the prisoner is because the difference of
opinion among some of the judges in those cases is as nothing
compared with the solemn decision of fifteen out of sixteen judges
in the case of Reg. v. Prince, Law Rep., 2 C. C. R., 154. So far
as I am aware, in none of the cases cited by my learned Brothers
was the interest of third parties, such as the fact of their being
children of the second marriage, involved. I have listened with
attention to the judgments which have been delivered, and I have
192 Cases on Criminal Law.
not heard a single observation with reference to this, to my mind,
important and essential point. I am absolutely unable to distin-
guish Reg V. Prince, Law Rep., 2 C. C. R., 154, from the present
case, and, looking to the names of the eminent judges who consti-
tuted the majority, and to the reasons given in their judgments, I
am of opinion upon authority as well as principle that the conviction
should be affirmed.
The only observation which I wish to make is (speaking for
myself only), that I agree with my learned brother Stephen in
thinking that the phrases " mens rea " and " non est reus nisi mens
sit rea " are not of much practical value, and are not only "likely
to mislead," but are " absolutely misleading." Whether they have
had that effect in the present case on the one side or the other it
is not for me to say.
I think the conviction should be affirmed. My brothers
Denman, Pollock, Field, and Huddleston agree with this judgment,
but my brother Denman has written a short opinion of his own,
with which my brother Field agrees.*
Conviction quashed?
HALSTEAD v. STATE.
Court of Errors and Appeals of New Jersey, 1879.
41 New Jersey Law, 552.
The defendant was the director of the board of freeholders
of the county of Hudson, and was indicted for a violation of the
act entitled " A supplement to an act entitled ' An act for the
punishment of crimes,'" approved March 27th, 1874, which is as
follows, viz. :
The act under which the indictment is sought to be sustained
is found in the laws of 1876, page 16 as follows :
"I. Be it enacted by the Senate and General Assembly of
1 Dissenting opinion of Denman, J., is omitted.
^ Accord: Adultery, Banks v. St., 96 Ala. 78 (1891). Contra, bigamy,.
C. V. Mash, 7 Mete. 472 (1844) ; Davis v. C, 13 Bush, 318 (1877) ; St. v.
Zichfeld, 23 Nev. 304 (1896) ; adultery, St. v. Goodenow, 65 Me. 30 (1876) ;
P. V. Hartman, 130 Cal. 487 (1900). — Ed.
Cases on Criminal Law. 193
the State of New Jersey, That if any board of chosen freeholders,
or any township committee, or any board of aldermen or common
councilmen, or any board of education, or any board of commis-
sioners of any county, township, city, town or borough in this
state, or any committee or any member of any such board or com-
mission, shall disburse, order, or vote for the disbursement of
public moneys, in excess of the appropriation respectively to any
such board or committee, or shall incur obligations in excess of
the appropriation and limit of expenditure provided by law for the
purposes respectively of any such board or committee, the mem-
bers thereof, and each member thereof, thus disbursing, ordering
or voting for the disbursement and expenditure of public moneys,
or thus incurring obhgations in excess of the amount appropriated
and limit of expenditure as now or hereinafter appropriated and
limited by law, shall be severally deemed guilty of malfeasance in
office, and on being thereof convicted shall be punished by fine not
exceeding one thousand dollars or imprisonment at hard labor for
any term not exceeding three years, or both, at the discretion of
the court."
The facts alleged in the indictment were, that at a meeting of
the board of freeholders, December 14th, 1876, a resolution was
adopted for purchasing certain land for a court-house site for the
sum of 11225,720, to be paid for in bonds of the county, "payable
out of the amount appropriated and limited for the next fiscal
year" — that is, for the fiscal year to commence December ist,
1877, "said bonds to run one year from date," &c. ; that the de-
fendant presided at this meeting and subsequently approved the
resolution, and, together with the county collector, signed the
bonds in accordance with the said resolution ; that the next fiscal
year after December 14th, 1876, would commence December ist,
1877, and that no appropriation or limit of expenditure had been
fixed for this latter year. It also appeared that for the fiscal year
commencing on December ist, 1876, the tax fixed by resolution
was the sum of ;g6oo,ooo.
Beasley, C. J.' When the state had closed, the defence
offered to show that the defendant, in aiding in the passage and
^Argument of counsel and part of opinion relating to another point
are omitted.
194 Cases on Criminal Law.
effectuation of the resolution which I have pronounced to be
illegal, did so under the advice of counsel, and in good faith, and
from pure and honest motives, and that he therein exercised due
care and caution. The arguments upon this interesting topic,
contained in the briefs of the respective counsel, marked, as such
briefs are, by acute reasoning and copious learning, have been of
much assistance in the examination of the subject.
On the part of the defence, it is strongly urged that the de-
fendant was not a volunteer in this affair; that he was bound,
under the obligations of public duty, to decide and act in the
premises, and that if he acted with an honest purpose, and with
due circumspection, to hold him guilty under this law would be
contrary to those essential principles of justice and public policy
on which all law is founded. To enforce this view, we are referred
to those general maxims of criminal law which have been so often
repeated by judges, and which are so well summarized by Mr.
Bishop in the first volume of his work on Criminal Law, section
two hundred and five, to the effect, " that in no one thing does
criminal jurisprudence differ more from the civil than in the rule
as to intent. Crime proceeds only from a criminal mind."
Looked at in this light, and in this general aspect, the position of
the defence is well calculated to strike the mind with great force,
for we have there as the elements of the juncture that the defendant
was honest, that he acted with caution, and that he was compelled
to act, so that his violation of law was an unavoidable resultant
from a discharge of duty, in its best form. It is, therefore, urged
that the result is that the rule of law that will convert the defendant
into a criminal is a rule that must inevitably, on many occasions,
lead to the inculpation, by force of the criminal law, of this class
of officials if they discharge their duty faithfully.
But it will be observed that the principle that infuses life into
this line of argument is too broad to be assented to in its full
extent. Nothing in law is more incontestable than that, with
respect to statutory offences, the maxim that crime proceeds only
from a criminal mind does not universally apply. The cases are
almost without number that vouch for this. The defendant in
this case pleads that he was ignorant of the law as applied to the
facts involved in his conduct But it has been many times decided,
and indeed is the admitted general rule, that ignorance of the law
Cases on Criminal Law. 195
is no defence against a criminal charge. Mr. Wharton, in an
article published in the Albany Law Journal on February 5th,
1879, page thirty-four, says " that ignorance of law is no defence
is generally admitted."
Mr. Broom, in his Legal Maxims, thus clearly delineates the
legal doctrine: "It is," says Lord Kehyon, "a principle of natural
justice, and of our law, that the intent and the act must both con-
cur to constitute the crime." "A man," as remarked by Earle,'
Chief Justice, " cannot be said to be guilty of a delict, unless, to
some extent, his mind goes with the act. And the first observa-
tion which suggests itself in limitation of the principle thus enun-
ciated, is that whenever the law positively forbids a thing to be
done, it becomes thereupon ipso facto illegal to do it wilfully, or,
tn some cases, even ignorantly, or, maybe, to effect an ulterior
laudable object, and consequently the doing of it may form the
subject matter of an indictment, or other legal proceedings sim-
pliciter, and without the addition of any corrupt motive."
In the case of State v. Goodenow, 65 Me. 30, it was decided,
on an indictment for adultery, that the defendant could not defend
on the plea that she belived that she had been legally divorced.
And, in like manner, it is easy to cite cases establishing the doc-
trine beyond dispute or cavil, that in many cases an honest mistake
in regard to a state of facts will not exculpate when the prohibi-
tion of a statute has been violated. As an illustration, I will refer
to Reg. V. Woodrow, 15 M. & W. 404, which was an information
against a retailer of tobacco, for having in his possession adulter-
ated tobacco ; and it was held that he was punishable, though it
was shown that he had purchased it as genuine, and had no knowl-
edge or cause to suspect that it was not so. Another example is
presented in Commonwealth v. Mash, 7 Mete. 472, which was the
case of a woman marrying after her husband had been absent for
several years, in the honest belief that he was dead ; such defence
being disallowed. But on this head it is not necessary to multiply
authorities. A crowd of them are collected in the brief of the
attorney-general, and in fact it is admitted by the counsel of the
■defence that in a large number of instances of statutory offences,
the crime may be committed in the absence of any wrongful
intent. Nor even with respect to the common law is it true that
a guilty purpose, or the possession of the knowledge requisite to
196 Cases on Criminal Law.
make the mind guilty with respect to a particular act, is an essen-
tial part of criminality. It is settled in that system by indubita-
ble authority, that a statute may be violated by a person so soon
after its passage that the fact of its enactment could not by possi-
bility have come to his knowledge. Judge Story, in one of his
decisions, recognizes this as an established principle of the com-
mon law, and applies it to the issue before him.
But, on the other hand, it is equally undeniable that in some
cases, when the prohibition in a statute against doing a certain act,
or series of acts, is couched in general terms, courts have, to use
the language of Lord Cockburn, imported into the statute a proviso
that the denoted act shall be done from a guilty mind. Such was
the case of Rider v. Wood, 2 E. & E. 338, which was an informa-
tion against the defendant for unlawfully absenting himself from
the service of his employer during the term of his contract of ser-
vice, contrary to a statute, the proceeding being founded on a law
which enacted that if any servant, &c., " shall contract with any
person or persons to serve him, &c., for any time or times what-
soever, and having entered into such service, shall absent himself
or herself from his or her service before the term of his or her
contract shall be completed, the person so offending may be com-
mitted," &c. The defendant having absented himself from the
service contracted for by him, under the honest behef that a notice
that he had served had legally dissolved the contract, the court
held that he could not be convicted if he had given the notice in
good faith, and believed in its legal efficacy, although in point of
law such notice was a nullity. This is manifestly a clear case in
which the court held that the culprit must have had a guilty mind,,
although such ruling had the effect of qualifying the general
statutory language. There are other cases in the same line cited in
the briefs.
Now these two classes of cases, diverging as they do, and^
seemingly standing apart from each other, may at first view appear
to be irreconcilable in point of principle ; but, nevertheless, such
is not the case. They all rest upon one common ground, and
that ground is the legal rules of statutory construction. None of
them can legitimately have any other basis. They are not the
products of any of the general maxims of civil or natural law-
On the contrary, each of this set of cases is, or should have been,.
Cases on Criminal Law. 197
the result of the judicial ascertainment of the mind of the legisla-
ture in the given instance. In such investigations the dictates of
natural justice, such as that a guilty mind is an essential element
of crime, cannot be the ground of decision, but are merely circum-
stances of weight, to have their effect in the effort to discover the leg-
islative purpose. As there is an undoubted competency in the law
maker to declare an act criminal, irrespective of the knowledge or
motive of the doer of such act, there can be, of necessity, no judicial
authority having the power to require, in the enforcement of the
law, such knowledge or motive to be shown. In such instances
the entire function of the court is to find out the intention of the
legislature, and to enforce the law in absolute conformity to such
intention. And in looking over the decided cases on the subject
it will be found, that in the considered adjudications, this inquiry
has been the judicial guide. And naturally, in such an inquiry,
the decisions have fallen into two classes, because there have been
two cardinal considerations of directly opposite tendency, influenc-
ing the minds of judges ; the one being the injustice of punishing
unconscious violations of law, and the other the necessity, in view
of public utility, of punishing, at times, some of that very class of
offences. All the cases that are pertinent that are relied upon by
the counsel of the defendant in this case, are decisions that have
been produced mainly under the influence of the former of these
two classes of considerations, but they are all, nevertheless, mere
constructions of the respective statutory enactments. These cita-
tions are made with a view to show that as a general rule the
courts will require a corrupt motive to be shown when the statutory
denunciation against doing an act contains no such requisition.
But the authorities vouched do not sustain that large proposition ;
they simply evince that in those special instances in construing the
respective enactments, a legislative purpose was perceived of
requiring, to constitute the offence, a mind conscious at the time of
wrongdoing. The decisions thus adduced are not many; some
of them are not apposite to the question ; and none of them can
be said to sustain the proposition that in cases where a statute in
general terms prohibits the doing of a particular act, the court
will interpolate into such statute the requirement of a corrupt
motive as an ingredient of the offence, on the sole ground that
otherwise it would be opposed to natural justice. For a moment
198 Cases on Criminal Law.
I will turn my attention to these cases, to see how far they sustain
the proposition above stated, or the kindred proposition that a
misapprehension as to the legal application of a statutory prohibition
will excuse its infringement. The two cases of Rex v. Jackson, i
T. R. 653, and Rex v. Barrat, Doug. 449, have no relevancy, as
they were motions for informations, and were therefore applica-
tions addressed to the discretion of the court. The next case is
that of Commonwealth v. Bradford, 9 Mete. 268, in which the in-
dictment was for illegal voting, but it can have no appreciable
bearing upon the present inquiry, for although it was indeed held
that a mistake with reference to the law might be proved, it ap-
peared that the statute alleged to have been violated, made a
knowledge of the law a component part of the offence. The act
imposed a penalty on a person who should vote "knowing himself
not to be a qualified voter ; " and the court sanctioned the admis-
sion of evidence tending to show an honest error as to the law.
I do not think that it is to be questioned that where a corrupt pur-
pose or guilty knowledge is a part of the crime, ignorance of the
law may be shown. The recent case of State v. Noyes, was
affected by such a circumstance, and the defendant was permitted
to show, in repulsion of the charge of fraud, that he was honestly
mistaken as to the law and that he acted under the advice of
counsel. In the present case, if this act of 1876 had declared that
if any member of the board of freeholders should corruptly con-
tract a debt in excess of the prescribed limit, there would not
upon this point have been any question worthy of a moment's dis-
cussion. The next case, which is that of Commonwealth v. Shedd,
I Mass. 228, is subject to this same criticism.
The next case is the anonymous one taken from 2 East P. C.
765, and it, with respect to its enactment, was this : A statute
made it an indictable offence for any person to have in his posses-
sion any canvas stamped with the king's mark, unless such person
had a certificate of an officer of the crown showing how such
article came into his possession. The defendant, who was a
woman, was found with such a piece of canvas in her possession,
and had no certificate showing how it came to her. On the trial,
it appeared that the defendant's husband had purchased it in his
lifetime at a public sale by the officers of the navy, and had used
it in the family, and that it had been left in the house at his death,
Cases on Criminal Law. i 99
and that no certificate appeared to have been taken at the sale.
It was obvious that the defendant was morally not guilty and the
court pronounced her legally not guilty. As far as appears there
was no attempt to put any construction on the statute, derived from its
language or the object at which it aimed, but the case as reported
was disposed of by the remark made apparently to the jury, that
" if the defendant's husband really bought the Hnen at public sale,
but neglected to take a certificate, or did not preserve it, it would
be contrary to natural justice, after such a length of time, to punish
her for his neglect." This as an observation to the jury would
not be out of the way, but as lapse of time could have nothing to
do with the matter in its legal aspect, it would be an improbable
conclusion to infer that the judge in these expressions was assign-
ing his grounds for holding this law inapplicable if the defendant's
possession of this article was unconsciously wrongful. But I do
not think this case, from extrinsic considerations, of much force as
a precedent. It is true that the judgment is said to have been
rendered, under the circumstances stated, by Judge Foster, who
in his day was eminent for his learning, especially in the field of
criminal law, but the case is not taken from the well-known
volume entitled " Foster's Reports," and which was prepared and
published by the judge himself, but from the appendix added by
another hand to the third edition, and which appendix is of no
authenticity, for we are informed by Mr. Dodson, in his life of
Judge Foster, that this appendix contains matters which the judge,
by the advice of Lord Mansfield and Lord Hardwicke, had himself
suppressed. I also observe that in the preface to his own edition
this venerable magistrate says that he is about to submit a few
crown cases in which he had taken a share, and that his other
notes "are too crude and imperfect to admit of publication," and
yet it is from these notes that the appendix in question has been
composed. It seems to me this case is of little account. More-
over, it is highly probable that it was, in point of fact, put on the
same ground with Reg. v. Sleep, 8 Cox's Crim. Cas. 472, which is
another authority cited for the defence, and which was the case of
a person indicted under the same statutory provision for having in
his possession certain copper marked with an arrow, denoting that
it had formerly belonged to the government. The jury having
found that the evidence was insufficient to show that the copper
200 Cases on Criminal Law.
was thus marked, Cockburn, Chief Justice, and his associates
adjudged that there could be no conviction, the Chief Justice say-
ing that "the ordinary principle that there must be a guilty mind
to constitute a guilty act applies to this case, and must be imported
into this statute, as was held in Reg. v. Cohen, 8 Cox's Crim. Cas.
41, where this conclusion of law was stated by Hill, Justice, with
his usual clearness and power." It will be perceived that the
Chief Justice does not attempt to justify the implication made by
him, except by the reference to the judgment of Hill, Justice, in
the case named, so that we are constrained to refer to that deci-
sion for explanation, and by doing so, we find the enactment in
question is expounded in the usual way by a reference to its con-
text and its effects, and the conclusion arrived at that unless the
adjudged interpretation should be adopted the act would be run
into absurdity. No one can doubt that, granting these judicial
premises, the conclusion was in harmony with ordinary rules.
The remaining cases cited, Reg. v. Tinkler, i Fos. & F. 513 ;
Hearne v. Garten, 2 E. & E. 66 ; Rider v. Wood, 2 E. & E. 338 ;
Taylor I/. Newman, 4 B. & S. 89; Buckmaster v. Reynolds, 13
C. B. (N. S.) 62, and United States v. Connor, 3 McLean 572, are
all decided on the same principle that was applied in the last case
just specially noticed. It is in this class of decisions that the case
of State V. Cutter, 7 Vroom 125, is to be included.
These cases have been specially referred to by me, with the
purpose of illustrating by examples the conclusion already
expressed, that the subject under consideration is completely
embraced in the legal department of statutory construction, and
that each decided case rests on its own facts and particularities, and
that the maxim, "actus non facit reum. nisi mens sit rea," has no
controUing effect. That this maxim has, and should have, in every
doubtful case a decided influence, is not denied ; but it is intended
to be affirmed that when an act is prohibited in express terms by a
statute, such prohibition cannot be contracted so as to embrace
only such persons as guiltily do such act, by the unassisted force
of such maxim.
The course of the inquiry, therefore, has led to this point:
is there anything in the language of the statute now to be con-
strued, or in the legislative design displayed in it, or in the conse-
quences, if its terms are construed strictly, by force of which this
Cases on Criminal Law. 201
court can limit its operation to those only who act with conscious-
ness of violating the law ?
Now it is incontestable that, in view of the interpretation
above put upon this provision of the statute, the duty thereby
required of this defendant was of the simplest possible character.
According to that interpretation the legislature, in effect, said to
these freeholders, "yourselves fix the sum requisite for your
expenditure during the year, but you are interdicted from making
any payment or contracting any debt beyond such limit." I find
it impossible to regard such a prohibition as involving any idea of
complexity, or difficulty in its execution. To obey such an injunc-
tion seems, to my mind, a very intelligible matter indeed ; certainly
a duty much easier of performance than that of the retailer of
tobacco, mentioned in the case already cited from Meeson & Welsby,
who was enjoined, under a penalty, not to have in his' possession
any adulterated tobacco, and which duty, his counsel contended,
■could only be perfectly and certainly performed by having a chemi-
cal analysis made of each sample that he purchased. If the duty,
then, be a simple one, and not one which is subject to very great
•difficulties in its performance, there is nothing in the nature of the
.act prohibited from which the court can say, in the face of the
legislative language, that it was not the intention to make it appli-
cable to every one who should violate its letter. Counsel indeed
pressed upon the court the consideration that this statute, from the
infelicity of its phraseology, was, with respect to its purpose or
.application, open to much question, and that in point of fact pro-
fessional gentlemen had expressed variant opinions with regard to
it. This may be so, but when the question is as to the intention of
the legislature, this argument is out of place. It would be prepos-
terous for this court to hold that the legislature, in this act, has
intended to punish the person who infringes the letter of this law,
-without regard to the question of his moral delinquency, and at the
same time to say that such effect shall not be given to the statute,
because of the lame way in which it has been penned. This would be
to put the case upon the rejected ground of the hardship arising from
applying the law to a person whose mind was not guilty, instead
of abiding by the adopted doctrine of ascertaining the intention of
the law maker. The sole business of the court is to find the mean-
ing of this law, and then to give it effect in that sense. It will also
202 Cases on Criminal Law.
be observed that the result to which I have come, that this duty-
imposed on the freeholders is a plain one and one not difficult of
performance, dissipates all idea that the court can, by construction,
control the generality of its terms, on the ground that, read in its
rigor, it bears so hardly on this class of officers as to raise a pre-
sumption against such an interpretation. If there has been any
hardship, it has arisen from the verbal obscurity of the statute, and
such a consideration, it has been just remarked, ought not to affect
the mind of the court. Nor is it the province of the court to say
whether this law is too rigorous or not ; that is the part of the
legislature ; but it certainly is not clear that such a regulation may
not be subservient to a wise public policy. Entertaining the view
that the act which this defendant was ordered to abstain from doing
was neither difficult to comprehend or to perform, I find myself
unable to yield to the notion that the language of the provision in
question can be curtailed by construction.
The judgment should be affirmed}
For affirmance — The Chancellor, Chief Justice, Depue,
Reed, Scudder, Van Syckel, Woodhull, Clement, Dodd, Green,
Lilly — 1 1.
For reversal — None.
STERN V. STATE.
Supreme Court of Georgia, 1874.
53 Georgia, 229.
Myers Stern was tried at the November term, 1873, of the
county court of Clarke county for the offence of allowing a minor,
Frank Talmadge, to play at billiards without the consent of his
parent or guardian. The evidence made out a prima facie case
for the State, but for the defense it was shown that Stern, before
allowing Talmadge to play on his table, had inquired as to his age
^Accord: St. v. Huff, 89 Me. 521, (1897); Fraser v. St., 112 Ga. 13
(1900) ; St. V. Foster, 46 Atl. (R. I.) 833 (1900). — Ed.
Cases on Criminal Law. 203
and had been informed by said minor that he was an adult ; that
he appeared to be over twenty-one years of age, and that he was,
in fact, within six months of maturity at the time that he indulged
in the aforesaid game.
The county court refused to consider this testimony, holding
that upon proof of the playing of the game with the knowledge
of the defendant, of the minority of Talmadge, and of the absence
of the consent of his parent or guardian, conviction was the inevit-
able result.
The case was carried by certiorari to the Superior Court,
where the judgment of the county court was affirmed, and
defendant excepted.
T. W. Rucker, for plaintiff in error.
Emory Speer, Solicitor General, by W. B. Thomas, for the
State.
McCay, Judge.
1 . We agree with the counsel for the plaintiff in error that
the county judge did not take a proper view of the law on
the trial. To make a crime, there must be the union of act
and intent, or there must be criminal negligence. It is not con-
clusive evidence of guilt on the part of the defendant that he
permitted this young man to play at his table ; that the young
man was, in fact, a minor, and that the parent did not consent.
These facts, it is true, make a prima facie case, and if they stood
alone, the guilt of the defendant would be manifest ; but evidently
there was evidence of another element in the case, which, by the
return of the county judge, is shown not to have been considered
by him in arriving at his conclusion. There was evidence going to
show that the defendant might have been honestly mistaken as to
the age of the young man. It is clear to us that if the defendant,
after due diligence, thought honestly that this young man was not
a minor, he is not guilty. If he did so think, after proper inquiry,
the element of intent does not exist ; the act was done under a mis-
take of fact. In such a case, there is no guilt and no crime. This
is the doctrine of all the books, and is, besides, common sense and
common justice.
2. Nor is there anything in the nature of this offence which
alters the rule. If one who shoots down his dearest friend by
mistake, supposing him to be a dangerous wild beast or a burglar,
204 Cases on Criminal Law.
is not guilty of any crime, surely one who permits a minor to play
billiards without the consent of the parent, under the honest behef
that he is not a minor but of full age, is not guilty. In both cases,
however, to excuse the guilt there must be no want of proper cau-
tion on the part of the accused. He must have used due diligence,
according to the circumstances and the nature of the case. But if
he do this, and the evidence show that after such caution he is still
honestly mistaken he is not guilty. We are not prepared to say
that the evidence here is conclusive of an honest mistake. We do
not say that the defendant was bound to have inquired of the parent.
That would depend on his accessibility, and on the strength of the
other circumstances indicating full age. It is impossible to lay
down any general rule. Each case must depend on its own nature
and circumstances. From the very nature of this offense special
diligence is necessary. Everybody knows that there is uncer-
tainty in such cases, and as the law has made the age of any bil-
liard-player important, even in spite of this liability to mistake, every
saloonkeeper should act in view of the fact that he is dealing with
an uncertain thing. The man who throws a heavy weight from
the top of a building is bound to a greater caution if he does it in
a city or town, and into a street, than if he does it in the country,
and into a little traveled road. As we have said, we do not
think this evidence establishes conclusively that the defendant was
honestly mistaken. We incline to the opinion of Judge Rice that
there is some evidence to justify the finding, and had this convic-
tion been by the verdict of a jury, under a legal charge as to the
law, we should hesitate to disturb it. But the record shows the
county judge did not consider the question of intention ; he acted
on the idea, that as the proof was clear of minority, the law had
been violated, whatever might have been the honest opinion of the
defendant. He held him to be bound to inquire of the parent —
nay, on the general rule he acted on, he, perhaps, would have
found him guilty if he had inquired of the parent — had the parent,
either by mistake, or untruthfully, answered that the son was of
age. It appears therefore, that on the trial of this case, the judge,
who acted as judge and jury, mistook the law, did not consider the
evidence going to show an honest mistake, after due caution, and
we send the case back to be tried again under a proper view of the
law, to-wit : the defendant is not guilty, if, under all the circum-
Cases on Criminal Law. 205.
stances, he honestly thought the young man not to be a minor, and
the dihgence required is that reasonable diligence which, in view
of the nature of the case, a good citizen and prudent maa
would use.
Judgment reversed. ^
COMMONWEALTH v. WEISS.
Supreme Court of Pennsylvania, 1890,
139 Pennsylvania, 247.
Opinion, Mr. Justice Clark.'
This was an action brought to recover the penalty of ^100,.
provided for in the third section of the Act of May 21, 1885, P.
L. 22, commonly known as the Oleomargarine Act. At the trial,,
the defendant submitted a point requesting the court to instruct
the jury " that, if they (the jury) believe, from the evidence, that
the defendant did not knowingly furnish, or authorize to be
furnished, or know of being furnished, to any of his customers, any
oleomargarine, but, so far as he knew, furnished genuine butter,,
then the verdict must be for the defendant." The point was
refused, and whether the court was right in refusing it, as we
understand the case, is the only question upon which a decision is-
desired. The argument contained in the paper book, as well as-
the oral argument in this court, was directed to this question only,
and we assume that the parties intended to raise no other. That
portion of the charge in which binding instructions were given to
1 Accord : Selling liquor to minors, P. v. Welch, 71 Mich. 548 (1888);
[Contra : St. v. Hartfiel, 24 Wis. 60 (1869); Farmer v. P. 77 111. 322 (1875),;.
St. V, Cain, 9 W. Va. 559 (1876); C. v. Finnegan, 124 Mass. 324(1878);
Redmond v. St. 36 Ark. 58 (1880) ; St. v. Sasse, 6 S. D. 212 (1894) ; In re
Carlson's License, 127 Pa. 330 (1889);] Selling liquor to habitual drunkards,
Williams v. St 48 Ind. 306 (1874) ; Crabtree v. St. 30 Ohio St. 382 (1876) ;
Smith V. St. 55 Ala. i (1876). [Contra : Barnes v. St. 19 Conn. 398 (1849) ;.
St. V. Heck, 23 Minn. 549 (1877).] Having in possession counterfeiting tools,
P. V. White, 34 Cal. 183 (1867); Illegal voting by person under 21 years,
Gordon v. St. 52 Ala. 308 (1875); Permitting growth of Canada thistles,.
Story V. P. 79 111. App. 562 (1898). Contra : Allowing minors to loiter on
premises, St. v. Kinkead, 57 Conn. 173 (1889). -Ed.
2 The opinion only is printed.
2o6 Cases on Criminal Law.
find for the plaintiff, is not quoted in totidem verbis, in the assign-
ments of error, according to our rules ; it would seem, therefore,
that the appellant's intention is to confine our deliberations to the
single question referred to.
The first and third sections of the Act of 1885 provide as
follows : "
" I. That no person, firm, or corporate body shall manufac-
ture, out of any oleaginous substance or any compound of the
same, other than that produced from unadulterated milk or of
cream from the same, any article designed to take the place of
butter or cheese produced from pure unadulterated milk, or cream
from the same, or of any imitation or adulterated butter or cheese,
nor shall sell, or offer for sale, or have in his, her, or their posses-
sion with intent to sell the same as an article of food."
" 3. Every person, company, firm, or corporate body who
shall manufacture, sell, or offer or expose for sale, or have in his,
her, or their possession with intent to sell, any substance, the
manufacture and sale of which is prohibited by the first section of
this act, shall, for ever>' such offence, forfeit and pay the sum of
one hundred dollars, which shall be recoverable, with costs, by any
person suing in the name of the commonwealth, as debts of like
amount are by law recoverable," etc.
Guilty knowledge or guilty intent is, in general, an essential
element in crimes at the common law, but statutes providing
police regulations, in many cases make certain acts penal, where
this element is wholly disregarded. The distinction is thus laid
down in 3 Greenl. Ev., § 21 : "The rule" (i. e., that ignorance of
fact will excuse) " would seem to hold good in all cases where the
act, if done knowingly, would be be malum in se. But, where a
statute commands that an act be done or omitted, which, in the
absence of such statute, might have been done or omitted without
culpability, ignorance of the fact or state of things contemplated by
the statute, it seems, will not excuse its violation. Thus, for
example, where the law enacts the forfeiture of a ship having
smuggled goods on board, and such goods are secreted on board
by some of the crew, the owners and officers being alike inno-
cently ignorant of the fact, yet the forfeiture is incurred notwith-
standing their ignorance. Such is also the case in regard to many
other fiscal, police, and other laws and regulations, for the mere
Cases on Criminal Law. 207
^violation of which, irrespective of the motives or knowledge of the
party, certain penalties are enacted ; for the law in these cases
seems to bind the parties to know the facts, and to obey the law
at their peril." To the same effect, also, is Wharton, Crim. Law,
■§§ 83, 2442.
Whether a criminal intent, or a guilty knowledge, is a neces-
sary ingredient of a statutory offence, therefore, is a matter of
-construction. It is for the legislature to determine whether the
public injury, threatened in any particular matter, is such and so
great, as to justify an absolute and indiscriminate prohibition.
Even if, in the honest prosecution of any particular trade or
business, conducted for the manufacture of articles of food, the
product is healthful and nutritious, yet, if the opportunities for
fraud and adulteration are such as to threaten the public health,
it is undoubtedly in the power of the legislature, either to punish
those who knowingly traffic in the fraudulent article, or, by a
sweeping provision to that effect, to prohibit the manufacture and
sale altogether. The question for us to decide, therefore, is whether
or not, from the language of the statute, and in view of the mani-
fest purpose and design of the same, the legislature intended that
the legality or the illegality of the sale should depend upon the
ignorance or knowledge of the party charged.
The statute in question was an exercise of the police power,
and the act was sustained upon this ground, not only in this court,
but also in the Supreme Court of the United States : Powell v.
Commonwealth, 114 Pa., 265 ; Powell v. Pennsylvania, 127 U. S.,
678. The prohibition is absolute and general ; it could not be
expressed in terms more explicit and comprehensive. The statu-
tory definition of the offence embraces no word implying that the
forbidden act shall be done knowingly or wilfully, and, if it did,
the design and purpose of the act would be practically defeated.
The intention of the legislature is plain, that persons engaged in
the traffic shall engage in it at their peril, and that they cannot set
up their ignorance of the nature and qualities of the commodities
they sell, as a defence.
In Massachusetts, a statute declared that if any person should
"sell, keep, or offer for sale, adulterated milk," he should be
punished, etc. ; and it was held that the penalty was incurred,
although the sale was made without any knowledge of the adul-
2o8 Cases on Criminal Law.
teration, as when the seller had bought the milk for pure milk r
Commonwealth v. Farren, 9 Allen, 489 ; Commonwealth v.
Nichols, 10 Allen, 199. Upon the same ground, it has been held
and it is familiar law, that the statutes against selling intoxicating
liquors are violated, although the vendor does not know that it is
intoxicating: Commonwealth v. Boynton, 2 Allen, 160; Common-
wealth V. Goodman, 97 Mass., 117; Commonwealth v. Hallett,
103 Mass., 452. Where a statute imposed a penalty upon " any
person who shall sell, or keep for sale, naptha, under any assumed
name," a party charged with the offence was held to be guilty,
although he was not aware that the article sold was naptha, but
believed it to be some other oil : Commonwealth v. Wentworth,
118 Mass., 441. So, where a party is charged with furnishing^
liquors to minors, or for permitting a minor to play billiards in his
saloon, he is not permitted to set up his ignorance of the minor's
age to defeat the charge : Wharton Crim. Law, § 2442, and cases
there cited. In our own case. In re Carlson's License, 127 Pa.,
330, Carlson, in a proceeding to revoke his liquor license, under
the Act of May 13, 1887, P. L., 113, was charged with furnishing
liquors to minors, in violation of the seventeenth section of the
same act. He admitted the sale of liquors to the minors in ques-
tion. His excuse was that their appearance indicated that they
were of full age, and that, as a precaution before selling, he asked
their age, and each responded that he was of full age ; that he sold
to them in good faith, fully believing them to be so. Under the
Act of 1854, a necessary element to constitute the offence was that
the sale should be wilful, but in the Act of 1887 the word "wilfully"
was omitted, and it was enacted " that it shall not be lawful for any
person, with or without license, to furnish by sale, gift, or other-
wise," "any spirituous, vinous, malt or brewed liquors," "at any
time, to a minor." His license having been revoked, the case was
brought here for review, and the proceedings were affirmed. Chief
Justice Paxson, delivering the opinion of the court said : " If
we look into the opinion of the court for the facts, we find nothing
to help the plaintiffs. From it we learn that the offence of which
the plaintiffs in error were guilty was that of selling hquors to
minors, and that the only excuse offered was that they did not
know that the persons to whom they sold were minors. This
ignorance is not a sufficient excuse or justification under the act of
Cases on Criminal Law. 209
assembly. If such a defence could be successfully interposed in
such cases, there would be few convictions, and the law would be
nullified for all practical purposes." To the same effect are Com-
monwealth V. Sellers, 130 Pa., 32; Commonwealth v. Holstine,
132 Pa., 3 57, and Commonwealth v. Zelt, 138 Pa., 615. We are
of opinion that judgment was rightly entered for the plaintiff, and
the judgment is
Affirmed}
STATE V. WRAY.
Supreme Court of North Carolina, 1875.
72 North Carolina, 253.
Settle, J. The defendants being indicted for retailing spirit-
uous liquors, without a license so to do, the jury rendered the follow-
ing special verdict : " The defendants were druggists and partners in
the town of Shelby, and kept medicines for sale, but had no license to
retail spirituous Uquors. In the month of July, 1872, Dr. O. P.
Gardner, a practicing physician in the town of Shelby, prescribed
the use of a half pint of French brandy for Mrs. Durham, the wife
of the witness, Hill Durham, and directed the witness to go to the
defendants for it. That Dr. Gardner also went to the defendants
and directed them to let the witness have the said brandy for his
wife as medicine. The witness then went to the defendants and
purchased the half pint of French brandy, and his wife used it as
medicine. That French brandy is a spirituous liquor ; that it is also
an essential medicine, frequently prescribed by physicians, and often
1 Accord: Selling adulterated food, C. v. Farren, 91 Mass., 489 (1864),
St. V. Smith. 10 R. I., 258 (1872), P. v. Kibler, 106 N. Y., 321 (1887), St.z/.
Newton, 50 N.J. L. 534 (1888), St v. Kelly, 54 Ohio St., 166 (1896), selling
intoxicating liquor, King v. St., 66 Miss., 502 (1889), C. v. O'Kean, 152
Mass., 584 (1891); contra: Farrell v. St., 32 Ohio St., 456 (1877).
Having in possession adulterated tobacco, Reg. v. Woodrow, 15 M. &
W., 404 (1846) ;
Selling vinegar below standard, P. v. Worden Grocer Co., 118 Mich.,
604 (1898);
Removing timber from school lands, St. v. Dorman, 9 S. D., 528
(1897).— Ed.
2IO Cases on Criminal" Law.
used, and that in this case it was bought in good faith as a medi-
cine, and was used as such.
The letter of the law has been broken, but has the spirit of the
law been violated ? The question here presented has been much
discussed, but it has not received the same judicial determination in
all the States in which it has arisen. In this conflict of authority
we shall remember that the reason of the law is the life of the law,
and when one stops the other should also stop.
What was the evil sought to be remedied by our statute ?
Evidently the abusive use of spirituous liquors, keeping in view at
the same time the revenues of the State. The special verdict is
very minute in its details, and makes as strong a case for the defend-
ants as perhaps will ever find its way into court again. A phy-
sician prescribes the brandy as a medicine for a sick lady, and directs
her husband to get it from the defendants, who are druggists. It
may be that a pure article of brandy, such as the physician was will-
ing to administer as a medicine, was not to be obtained elsewhere
than at the defendants' drug store. The doctor himself goes to the
defendants and directs them to let the witness have the brandy as
a medicine for his wife. And the further fact is found, which per-
haps might have been assumed without the finding, that French
brandy is an essential medicine, frequently prescribed by physicians
and often used ; and the farther and very important fact is estab-
lished, that in this case it was bought in good faith as a medicine,
and was used as such. After this verdict we cannot doubt that the
defendants acted in good faith and with due caution in the sale
which is alleged to be a violation of law.
In favor of defendants, criminal statutes are both contracted
and expanded, i Bishop, par. 261. Now unless this sale comes
within the mischief which the statute was intended to suppress, the
defendants are not guilty ; for it is a principle of the common law,
that no one shall suffer criminally for an act in which his mind does
not concur. The familiar instance given by Blacksto^pe illustrates
our case better than I can do by argument. The Bolognian law
enacted " that whosoever drew blood in the street, should be pun-
ished with the utmost severity." A person fell down in the street
with a fit, and a surgeon opened a vein and drew blood in the street.
Here was a clear violation of the letter of the law, and yet from that
day to this, it has never been considered a violation of the spirit of
Cases on Criminal Law. 211
the law. Perhaps it will give us a clearer view of the case if we
put the druggist out of the question, and suppose that the physician
himself, in the exercise of his professional skill and judgment, had
furnished the liquor in good faith as a medicine. Can it be pre-
tended that he would be any more guilty of a violation of our stat-
ute than the surgeon was guilty of a violation of the Bolognian law ?
"We think not.
But we would not have it understood that physicians and drug-
gists are to be protected in any abuse of the privilege. They are
not only prohibited from selling liquor in the ordinary course of
business, but also from administering it as a medicine unless it be
•done in good faith, and after the exercise of due caution as to its
necessity as a medicine. The sale of liquor without a license, in
quantities less than a quart, is prima facie unlawful, and it is incum-
bent upon one who does so sell, to show that it was done under
circumstances which render it lawful. In this case we think such
•circumstances have been shown, and we concur in the judgment of
his Honor, that the defendants are not guilty.
Per Curiam. Judgment affirmed.
SECTION VI.
CONCURRENCE OF SEVERAL INTENTS.
REX V. WILLIAMS.
Kings Bench, 1795.
I Leach Crown Cases, 529.
Mr. Justice Ashurst.^ Rhenwick Williams, the prisoner at the
bar, was tried in the, last July Session on the Statute of 6 Geo. i.,
c. 23. And the indictment charged, that he, on the i8th January,
1790, at the parish of St. James, in a certain public street called St.
■■ Part of this case is omitted.
212 Cases on Criminal Law.
James's Street, wilfully, maliciously and feloniously did make an
assault ovi Anne Porter, spinster, with intent wilfully and maliciously
to tear, spoil, cut, and deface her garments ; and that he, on that
said i8th of January, 1 790, in the parish aforesaid, &c. , did wilfully,
maliciously, and feloniously tear, spoil, cut, and deface her silk
gown, petticoat, and shift, being part of the wearing apparel which
she then had and wore on her person. The jury found the prisoner
Guilty; but the judgment was respited, and the case submitted ta
the consideration of the judges upon three questions.
The judges areof opinion, that the case, as proved, is not sub-
stantially within the meaning of the Act of Parliament. This
statute was passed upon a particular and extraordinary occasion.
Upon the introduction of Indian fashions into this country, the silk
weavers, conceiving that it would be detrimental to their manufac-
ture, made it a practice to tear and destroy the clothes and gar-
ments which were of a different commodity from that which they
wove, and to prevent this practice the statute of 6 Geo. i., c. 23
was made. To bring a case therefore within this statute, the
primary intention must be the tearing, spoiling, cutting, or defacing
of the clothes ; whereas, in the present case, the primary intention
of the prisoner appears to have been the wounding of the person.
of the prosecutrix. The Legislature, at the time they passed this
Act, did not look forward to the possibility of a crime of so diaboli-
cal a nature as that of wounding an unoffending person merely for
the sake of wounding the person, without having received any
provocation whatever from the party wounded. But even upon the
supposition that it was possible for the Legislature to entertain an
idea of such an offence, it is clear they did not intend to include it
within the penalties of this statute, because, if they had entertained
such an idea, it is probable they would have annexed to it a higher
punishment than this statute inflicts. As the Legislature therefore
could not have framed this statute to meet this offence, it does not
fall within the province of those who are to expound the laws t&
usurp the office of the Legislature, and to bring an offence within
the meaning of an Act, merely because it is enormous, and
deserving of the highest punishment. But although the lash of the
Legislature does not reach this offence so as to inflict the conse-
quences of felony on the offender, yet the wisdom of the common
law opens a means of prosecution by indictment for the misdemeanor.
Cases on Criminal Law. 213
and, on conviction of the offender, arms the Court with a power to
punish the offence in a way that may force him to repent the
temerity of so flagrant a violation of the rules of law, the precepts
of social duty, and the feelings of humanity.^
REX V. GILLOW.
Court for Crown Cases Reserved, 1825.
I Moody, 85.
The prisoner was tried, and convicted before Mr. Justice
Bayley, at the Lancaster Lent assizes, in the year 1825, of mali-
ciously shooting at Dennis Carter, with intent to do him some
grievous bodily harm. It appeared that the prisoner had just come
out of a wood, armed with a gun, illegally to kill game there,
between two and three o'clock on the morning of the 2d
November, 1824. He was skirting the wood to kill game there,
when three keepers who were upon the watch for poachers, sud-
denly sprung up, and were rushing forward to seize him, when the
prisoner fired his gun at one of the keepers, and hit him upon the
lower part of his back and buttocks.
The wound was not dangerous.
^ It seems that Mr. J. BuUer, at the subsequent consultation of the judges,
retained the opinion he had given to the jury, viz : that the case came within
the statute, because the jury, whose sole province it was to find the intent,
had expressly found that the intent of the prisoner was to wound the party by
cutting through her clothes, and therefore that he must have intended to cut
her clothes ; and for this opinion he relied upon the case of Cook and Wood-
burn, upon the statute 22 and 23, Car. II. c. I., commonly called the Coventry
Act, charging them in the words of the Act with an intention to maim a Mr.
Crisp. The fact of maiming was clearly proved, but the defendants insisted
that their intention was to murder him, and not to maim him, and therefore
that they were not within the statute. But Lord King said that the intention was
a matter of fact to be collected from the circumstances of the case, and as
such was proper to be left to the jury; and that if it was the intent of the
prisoners to murder, it was to be considered whether the means made use of
to accomplish that end and the consequences of those means were not likewise
in their intention and design ; and the jury found them guilty and they were
executed. But it seems that upon a subsequent occasion Willes, J., and
Eyre, B., expressed some dissatisfaction with this determination, and thought,
at least, that the construction ought not to be carried further, i East, 400
and 424.
214 Cases on Criminal Law.
The jury were of opinion that the prisoner's motive was to-
prevent his lawful apprehension, but that in order to effect that
purpose he had also the intention of doing to Carter some grievous
bodily harm.
It was objected, that the act having specified the intent to-
prevent lawful apprehension, as one of the intents made essential
to constitute the offense, and that being the main and principal
intent in this case, the indictment should have charged that as the
intent. The learned judge was of opinion that if both intents
existed, the question which was the principal and which was the
subordinate intention was immaterial ; but though the learned
judge did not reserve the point, he thought it right to submit the
case to the consideration of the judges. In Easter term, 1825,
the Judges (Best, L. C. J. and Littledale, J. absent) met and.
considered this case, and held that if both intents existed, it was
immaterial which was the principal and which the subordinate one,,
and that the conviction was therefore proper.^
1 Accord: Rex t/. Shadbolt, 5 Car. & P., 504 (1833) ; St. v. Mitchell,.
5 Ire. L., 350 (1845); P. V. CarmichaeU 5 Mich., 10 (1858); St. v. Clark,.
69 Iowa, 196 (1886). — Ed.
Cases on Criminal Law. 215
Chapter IV.
Negligence as Supplying Intent.
Touching the sin of homicide, appeals are made thus : Knot-
ting, who is here, appeals Carling, who is there, for that whereas
Cadi, the father (brother, son, or uncle) of this Knotting . . .
was struck on such a part of his body by a curable stroke (or had
such a curable disease or wound), for the cure whereof he had
placed himself under this Carling, who professed himself a master
of medical practice, there came this Carhng, and undertook the
case, and by his folly and negligence, etc., feloniously slew him.
Or thus : withdrew sustenance from him, whereby qn such a day,
etc., he slew him. Or thus : so long delayed his delivery [from
prison] that thereby he slew him.
Mirror of Justices {Sel. Soc.^ Ch. 15.
HULL'S CASE.
Old Bailey, 1664.
Kelyng, 40.
In the Sessions in the Old Bailey holden the 13th of January,
1664, one John Hull was indicted for the murder of Henry
Cambridge, and upon the evidence, the case was, that there were
several workmen about building of a house by the Horse Ferry,
which house stood about thirty feet from any highway or common
passage, and Hull being a master workman (about evening when
the master workman had given over work, and when the laborers
were putting up their tools), was sent by his master to bring from
the house a piece of timber which lay two stories high, and he
went up for that piece of timber, and before he threw it- down,
he cried out aloud, stand clear, and was heard by the
2i6 Cases on Criminal Law.
laborers, and all of them went from the danger but only Cam-
bridge, and the piece of timber fell upon him and killed him ;
and my Lord Chief Justice Hyde held this to be manslaughter, for
he said he should have let it down by a rope, or else at his
peril, be sure nobody is there ; but my Brother Wylde and
myself held it to be misadventure, he doing nothing but what is
usual for workmen to do ; and before he did it, crying out aloud,
stand clear, and so gave notice if there were any near they
might avoid it ; and we put the case ; a man lopping a tree,
and when the arms of the tree were ready to fall, calls out to
them below, take heed, and then the arms of the tree fall
and kill a man, this is misadventure ; and we showed him Poulton
de pace 120, where the case is put, and the book cited, and
held to be misadventure ; and we said this case in question is
much stronger than the case where one throws a stone or shoots
an arrow Over the wall or house, with which one is slain, this
in Kelloway 108 and 136, is said to be misadventure. But we
did all hold that there was a great difference betwixt the case in
question.the house from which the timber was thrown standing thirty
foot from the highway or common footpath, and the doing the same
act in the streets of London ; for we all agreed, that in London,
that if one be a cleansing of a gutter, called out to stand aside, and
then throw down rubbish, or a piece of timber, by which a man is
killed, this is manslaughter ; being in London, there is a con-
tinual concourse of people passing up and down the streets, and a
new passenger, who did not hear him call out, and therefore the
casting down any such thing from a house into the streets, is like
the case where a man shoots an arrow or gun into a market-place
full of people, if any one be killed it is manslaughter; because in
common presumption his intention was to do mischief, when he
casts or shoots any thing which may kill among a multitude of
people ; but in case that an house standing in a country town
where there is no such frequency of passengers, if a man call out
there to stand aside, and take heed, and then cast down the filth
of a gutter, etc., my Brother Wylde and I held that a far different
case from doing the same thing in London. And because my
Lord Hyde differed in the principal case, it was found specially,
but I take the law to be clear, that it is but misadventure.
■ ' Cases on Criminal Law. 217
KNIGHT'S CASE.
Lancaster Assizes, 1828.
I Lewin C. C, i68.
Prisoner was indicted for manslaughter. The evidence was,
that, being employed to drive a cart, he sat in the inside instead of
attending at the horse's head, and while he was there sitting, the
cart went over a child who was gathering up flowers in the road.
Per Bayley, J. " The prisoner, by being in the cart instead
of at the horse's head, or by its side, was guilty of negligence ;
and, death having been caused by such negligence, he is guilty of
manslaughter."
Note. — A similar case occurred before Hullock, B., at the
York Spring Assizes, 1829, and a similar judgment w^s delivered.
RIGMAIDON'S CASE.
Lancaster Assizes, 1833.
I Lewin C. C, 180.
Prisoner, a wine merchant at Liverpool, was indicted for man-
slaughter, in having, by negligence in the manner of slinging a
cask or puncheon, caused the same to fall and kill two females
who were passing along the causeway. It appeared in evidence
that there were three modes of slinging casks customary in Liver-
pool : one by slings passed round each end of the cask ; a second,
by can -hooks ; and a third, in the manner in which the prisoner
had slung the cask, which caused the accident, viz., by a single
rope round the center of the cask.
The cask was hoisted up to the fourth story of a warehouse,
and on being pulled end-ways towards the door, it slipped from the
rope as soon as it touched the floor of the room.
2i8 Cases on Criminal Law.
Per Parke, J., to the jury : " The double slings were
undoubtedly the safest mode ; but if you think the mode which
the prisoner adopted, viz., that of a single rope, was reasonably
sufficient, you cannot convict him."
Prisoner was convicted and sentenced to a month's imprison-
ment.
STATE V. O'BRIEN.
Supreme Court of New Jersey, 1867.
32 New Jersey Law, 169.
Dalrimple, J.' On the fifteenth day of November, 1865, the
defendant was a switch-tender, in the employ of the New Jersey
Railroad and "Transportation Company. His duty was to adjust,
and keep adjusted, the switches of the road at a certain point in the
city of Newark, so that passenger trains running over the road
would continue on the main track thereof, and pass thence to the
city of Elizabeth. He failed to perform such duty, whereby a
passenger train of cars, drawn by a locomotive engine, was
unavoidably diverted from the main track to a side track, and
thence thrown upon the ground. The cars were thrown upon
each other with great force and violence, by means whereof one
Henry Gardner, a passenger upon the train, was so injured that he
died. The defendant was indicted for manslaughter, and convicted
upon trial in the Essex Oyer and Terminer. He insisted, and in
different forms, asked the court to charge the jury, that he could
not legally be convicted, unless his will concurred in his omission
of duty ; the court refused so to charge. A rule to show cause
why the verdict should not be set aside was granted, and the case
certified into this court for its advisory opinion, as to whether there
was any error in the charge of the court below, or in the refusal to
charge, as requested.
The indictment was for the crime of manslaughter. If the
defendant's omission of duty was wilful, or in other words, if his
^ The opinion only is printed.
Cases on Criminal Law. 219
will concurred in his negligence, he was guilty of murder. Intent
to take life, whether by an act of omission or commission, distin-
guishes murder from manslaughter. In order to make out against
the defendant the lesser offence of manslaughter, it was not neces-
sary that it should appear that the act of omission was wilful or
of purpose. The court was right in its refusal to charge, as
requested.
The only other question is, whether there is error in the
charge delivered. The error complained of is, that the jury were
instructed that a mere act of omission might be so criminal or
culpable as to be the subject of an indictment for manslaughter.
Such, we believe, is the prevailing current of authority. Professor
Greenleaf, in the third volume of his work on evidence, § 129, in
treating of homicide, says : " It may be laid down, that where one,
by his negligence, has contributed to the death of another, he is
responsible. The caution which the law requires in all these cases,
is not the utmost degree which can possibly be used, but such
reasonable care as is used in the like cases, and has been found, by
long experience, to answer the end." Wharton, in his Treatise
on Criminal Law, p. 382, says ; " There are many cases in which
death is the result of an occurrence, in itself unexpected, but which
arose from negligence or inattention. How far in such cases the
agent of such misfortune is to be held responsible, depends upon
the inquiry, whether he was guilty of gross negligence at the time.
Inferences of guilt are not to be drawn from remote causes, and the
degree of caution requisite to bring the case within the limits of
misadventure, must be proportioned to the probability of danger
attending the act immediately conducive to the death." The propo-
sitions so well stated by the eminent writers referred to, we beheve
to be entirely sound, and are applicable to the case before us.
The charge, in the respect complained of, was in accordance with
them. It expressly states, that it was a question of fact for the
jury to settle, whether the defendant was, or was not guilty of
negligence ; whether his conduct evinced under the circumstances
such care and diligence as were proportionate to the danger to life
impending. The very definition of crime is an act omitted or
committed in violation of public law. The defendant in this case
omitted his duty under such circumstances, as amounted to gross
or culpable or criminal negligence. The court charged the jury.
220 Cases on Criminal Law.
that if the defendant, at the time of the accident was intending to
do his duty, but in a moment of forgetfulness omitted something
which any one of reasonable care would be likely to omit, he was
not guilty. The verdict of guilty finds the question, in fact,
involved in this proposition against the defendant, and convicts him
of gross negligence. He owed a personal duty not only to his
employers, but to the public. He was found to have been grossly
negligent in the performance of that duty, whereby human life
was sacrificed. His conviction was right, and the court below
should be so advised.^
REGINA V. MACLEOD.
Court of Criminal Appeal, 1874.
12 Cox C. C, 534.
Alexander Macleod was charged with the manslaughter of
his wife, Annie Macleod, at Carlisle, on the 15th of October, 1873.
Thurlow and T. F. Fenwick were for the prosecution.
Charles Russell, Q. C. , and Fawcett were for the defence.
The case against the prisoner was that of having unlawfully killed
his wife by having administered to her a large quantity of a certain
' Accord: Reg. v. Pargeter, 3 Cox C. C, 191 (1848); Reg. v. Hughes,
7 Cox C. C, 301 (1857) ; cf. Rex v. Green, 7 Car. & P., 156 (1835). See
also U. S. V. Knowles, 4 Sawy. , 517 (1864): Thomas v. P. .2 Colo. App.,
513 (1892).— Ed.
"If the prisoner is and has been afflicted in the manner claimed
[with somnambulism] and knew, as he no doubt did, his propensity to do
acts of violence when aroused from sleep, he was guilty of a grave breach of
social duty in going to sleep in the public room of a hotel with a deadly
weapon on his person, and merits, for that reckless disregard of the safety of
others, some degree of punishment, but we know of no law under which he
can be punished. Our law only punishes for overt acts done by responsible
moral agents. If the prisoner was unconscious when he killed the deceased,
he cannot be punished for that act, and as the mere fact that he had a weapon
on his person and went to sleep with it there did no injury to any one, he
cannot be punished for that." Cofer J. in Fain v. C, 78 Ky. 183(1879).
Cases on Criminal Law. 221
drug called muriate of morphia. From the evidence it appeared
the prisoner, who had been for about twenty or thirty years a sur-
geon on the medical staff of the Madras Army in India, came over
to live in England, about a year and a half or two years ago, and
shortly after came to Carlisle, and brought with him the deceased
woman his, wife. For a short time before the 1 5th of October,
while the prisoner and his wife were living together in Chiswick
street, Carlisle, one of their children, who was about six years of
age, became ill of typhoid fever, and for a fortnight before that
the deceased woman had been in a bad and weak state of health.
That indisposition was materially increased by having to attend to
her sick child, which she had done most assiduously, and for
several days previous to the 15th of October, she appeared never
to have obtained good rest. In the middle of that day — the 1 5th
of October — she appeared very unwell indeed, and the prisoner,
finding she had not obtained any proper rest, determined to give
her an opiate. At 4 p. m. he went to Mr. Todd, a chemist in the
town, and there obtained in a bottle twenty grains of morphia, and
paid eightpence for it, that being the price of that quantity to a
medical man. The prisoner went home, gave his wife one grain,
after weighing it, and repeated other does without weighing them ;
altogether he administered something like sixteen and a half grains
before seven o'clock that evening, in about three or three and a
half hours. About 6.30 the prisoner went for Dr. Walker, and told
him his wife had taken too much morphia, and as they were pro-
ceeding from Dr. Walker's house to the prisoner's they had a
conversation in which the prisoner stated that he had given her
repeated doses of morphia, that he had given her one grain as a
first dose which he had weighed, but that in repeating the doses he
had not weighed them, but guessed the quantity. Dr. Walker on
his arrival found the poor woman lying on the hearth rug in front
of the fire suffering from pain and apparently unconscious. Dr.
Walker tried various means of restoring her. At twenty minutes
before nine o'clock, Dr. Maclaren was called in and he injected
atropine as an antidote. The deceased was then in a state almost
comatose, and it was found impossible to rouse her. She died at
ten o'clock, having all the symptoms of death by morphia. Under
these circumstances it was submitted by the prosecution that the
conduct of the prisoner had been so heedless and reckless in giving
222 Cases on Criminal Law.
such large doses of morphia, that he was criminally liable and was
guilty of the offence of manslaughter.-^
Denman, J., in summing up the case to the jury, said, the law
was this, whether a man be a medical man or not, if he dealt with
dangerous medicines he was bound to use them with proper skill,
and was bound to bring proper care, and employ proper caution,
so that persons should not be endangered by want of skill, on his
part,or want of caution or care in dealing with those deadly ingred-
ients. Whether it be deadly weapons, or drugs, the law was the
same, and it made no difference whether a medical man was
dealing with a patient or, as a volunteer, dealing with his friend or
his wife. The jury might be enlightened by looking at the rela-
tions between the parties, and he was by no means prepared to say
that, in judging of the evidence, it would not enhghten them very
much, and enable them to appreciate the evidence on the main
point, whether the man did not do his best, not in the sense of
doing a bad best — but doing a good best, he being a medical man
and therefore likely to know whether a drug was likely to be
dangerous in the quantity administered or innocuous. There was
ample evidence that the death of the deceased was caused by mor-
phia. There was great difference of opinion as to the quantity of
the drug which could be administered safely ; however, if the jury
were satisfied that the death was caused by morphia ; and if it was
administered without proper care, skill, and caution, and without
a proper knowledge of morphia by the prisoner — whether in the
weighing of the drug, or in any other way that would be clear
negligence — he would not use the term " gross negligence," because
it was liable to misinterpretation — and if that was so, the prisoner
would be guilty of manslaughter. But if the drug was administered
without want of skill and intending to do for the best — doing noth-
ing, in fact, a skilful man might not do — then if the jury merely
thought it was some error of judgment which anybody might have
committed, the prisoner should be acquitted.
Not Guilty?
1 Part of this case is omitted.
2 Accord : St. v. Hardister, 38 Ark., 605 (1882) ; C. v. Pierce, 138 Mass.,
165 (1884).— Ed.
Cases on Criminal Law. 22^
REGINA V. SHEPHERD.
Court for Crown Cases Reserved, 1862.
I LeigA <&* Cave, 147.
The following case was reserved by Williams, J.
The prisoner was indicted for the murder of her daughter,
Mary Ann Ashton, and tried before me at the gaol delivery for
the county of Devon in December last.
The case for the prosecution was that the prisoner, having a
great ill-will towards the deceased, had purposely neglected to
procure a midwife, or other proper person, to attend her daughter,
when she was taken in labor ; and that, by reason thereof, she died
in child-birth. She was about eighteen years of age and unmarried.
The prisoner, nearly four years before the trial, had married a
second husband, who was not the father of the deceased. After
the marriage the deceased lived with her step-father and her mother
for some time, and then went out to service, occasionally returning
to live with them when she was out of place, and, at such times,
working at glove-making in order to earn her subsistence. About
the beginning of the harvest before her death (which took place
on October 26th, 1861), she came back from service to her step-
father's house, and continued to reside with her mother and her
step-father and their family until she died, except that she was
absent staying with an aunt near Bridgwater for about six weeks,
•whence she returned to her step-father's house on Tuesday, and
•continued there till the following Saturday, when she died.
At the close of the case for the prosecution, it was objected
by the counsel for the prisoner that she was under no legal duty or
obligation to procure, or try to procure, the attendance of a mid-
wife for her daughter, and therefore, that she was not criminally
responsible for neglecting to do so.
I told the jury to consider, whether it was established by the
evidence that the death of Mary Ann Ashton was attributable to
the prisoner's neglect to use ordinary diligence in procuring the
assistance of a midwife, or other proper attendant, and if it was not
so established, to acquit the prisoner ; but if it was so established,
then to consider, secondly, whether, by so neglecting, she intended
224 Cases on Criminal Law.
to bring about the death of her daughter, and if so, I told the jury-
to convict her of murder, but if not, of manslaughter.
The jury convicted her of manslaughter. But I respited the
judgment, in order to obtain the opinion of this Court, whether the
objection to the conviction was well founded.
This case was argued- on the 25th of January, 1863, before
Erle, C. J., WiGHTMAN, J., WiLLiAMS, J., WiLDE B. and Mellor, J.
The prisoner was unable, from poverty, to instruct counsel ;.
but, at the request of the Court, H. J. Cole, who had defended the
prisoner upon her trial, argued the case as amicus curia.
Cole. The conviction must be quashed. Previously to the
late statute, 14 & 15 Vict. c. 100, s. 4, the indictment must have set
forth the means by which the death of the deceased was caused. It
must have been caused either by an act of mis-feasance or non-
feasance. If the act is one of non-feasance, it must be shown that
the party charged was under an obligation to perform the act omit-
ted, and had the means of fulfilling that obligation.
Williams, J. It would have been sufficient if the indictment
had shown facts from which the duty would arise, without setting
forth the duty itself. The duty might be implied by law from the
facts stated.
Cole. No doubt. But there must be a duty, and the duty
must arise either from contract or relationship. Here there was
clearly no duty from contract ; but it is contended on the part of the
prosecution that, from the facts as stated, there arose a duty from the
relationship existing between the prisoner and the deceased. Now,
there was no duty on the mother or step-father here to support this
girl. The case of Regina v. St. Botolph's, Aldgate, Fol. 54, in which
it was held, upon the construction of the 43 Eliz., c. 2, s. 7, that a
step-father was bound to support his step-child during the Hfe of the
wife, has been overruled in the subsequent case of Rex v. Munden,.
I Str. 190, where it was held that the relationship meant by that stat-
ute was blood relationship only. The cases on the subject are fully
set out and commented upon in Cooper v. Martin, 4 East, 76; in
which Rex v. Munden was approved of and followed. It is submitted,
therefore, that neither the step-father nor the mother was bound to
support the woman's child by a former husband before the 4 & 5
Wm. 4, c. 76, s. s 7. That statute makes the step-father liable for
its support, until the child is sixteen, but not afterwards. Then, if
Cases on Criminal Law. 225
they are not bound to supply the child with food, neither are they
bound to supply it with medical attendance. In Rex v. Friend, Russ,
& Ry. 20, the general opinion of the Judges was, " That it was an in-
dictable offence, as a misdemeanor, to refuse or neglect to provide
sufficient food, bedding, &c., to any infant of tender years, unable to
provide for and take care of itself (whether such infant were child, ap-
prentice or servant), whom a man was obliged by duty or contract to
provide for, so as thereby to injure its health ; but that, in that case,
the indictment was defective in not stating the child to be of tender
years, and unable to provide for itself." In Russell on Crimes and
Misdemeanors, it is said that, where the wife is to be considered
merely as the servant of the husband, she will not be answerable for
the consequences of his breach of duty, however fatal : Rex v. Squire,
I Russ. C. & M. 19. Rexz/. Saunders, 7 C. & R 277, is to the same
effect. There Alderson, B., says, "The prisoner is indicted as a mar-
ried woman. If her husband supplied her with food for this child, and
she wilfully neglected to give it to the child, and thereby caused its
death, it might be murder in her. In these cases the wife is in the
nature of the servant of the husband. It does not at all turn upon
the natural relation of mother. To charge her, you must show
that the husband supphed her with food to give to the child and
that she wilfully neglected to give it."
Erle, C. J. The wife is not liable, unless it is shown that the
husband enabled her to perform the duty attempted to be cast upon
her.
Cole. No. The same point was similarly decided in Regina
V. Edwards, 8 C. & P. 611. There was no duty on the mother in
this case. The girl was of full age.
Williams, J. The verdict must be taken to have found that
the prisoner could have got a midwife, if she had chosen. I dis-
tinctly told the jury that if she had no means of obtaining the ser-
vices of a midwife, they ought to acquit her. It must be taken
that she had such means.
Mellor, J. And had funds ?
Williams, J. It did not appear whether she had funds or
not.
Erle, C. J. By ordinary care she might have got a midwife.
Wightman, J. That is, by going to a greater or less distance,
where a midwife would have been found, who would have attended.
226 Cases on Criminal Law.
Cole. It is admitted that there was the physical ability to get
a midwife ; but there was no legal duty requiring her to do so.
Wilde, B. Your argument is founded on the absence of any
legal obligation.
Cole. It is. Where there is no obligation there is no criminal
responsibility. There was no more duty on her to get a midwife
than on any stranger.
Wilde, B. You contend that the duty, if any, arising from the
presence of the girl in the house, bound the husband and not the wife.
Cole. I do. In Regina v. Chandler, Dears. C. C. 453, there
was no evidence that the prisoner, a single woman, had the actual
possession of means to support her child ; and, although it was
proved that she could have obtained such means by applying to the
relieving officer of the union, it was held that that was not sufficient.
There Pollock, C. B., says, " It is not sufficient to prove that the
prisoner might by possibility have obtained the necessary means."
In Regina v. Hogan, 2 Den. C. C. 277, judgment was arrested on
the ground that the indictment omitted to aver that the prisoner
had the means of supporting the child.
Erle, C. J. In Chandler's Case the prisoner had the means
in the sense that, if she had asked the relieving officer, she would
have obtained support for the child. So here the prisoner had
means in the sense that she could have asked the midwife to come
in. She had not what maybe called manual control of the means.
She had to go and ask a third person for help.
S. Carter {Bere with him) for the Crown. The cases cited do
not bear on the point in question. It was the natural duty of the
prisoner to take steps to preserve the life of her daughter ; Black-
stone's Commentaries by Stephen, Vol. 2, p. 281. The duty of
parents, towards their children, when young, is clear. It is not clear
that that duty ceases at any time. The duty here was incumbent
upon the wife, as the husband was absent the whole of the day.
Williams, J. That is a material fact and ought to have been
stated in the case. He had gone out for his day's work, and was
not at home, when his daughter was taken in labor.
Carter. The duty naturally incumbent on the woman is sup-
ported by the duty imposed by the 43 Eliz. c. 2, s. 7. That
statutory duty is continued by the 5 Geo. i, c. 8 ; the 59 Geo., 3,
c. 12, s. 26 ; and the 4 & 5 Wm. 4, c. 76. In Russell on Crimes,
Cases on Criminal Law. 227-
Vol. I, p. 493, by Greaves, there is a query by the learned editor,
whether cases may not occur where the wife would be legally bound
to apply for relief to the parish officers. That point came under dis-
cussion in Regina v. Vann, 5 Cox C. C. 379. In Regina v. Mabbett,
5 Cox C. C. 339, Erle, J., is said to have been of opinion "that a
woman who, having a child, neglects for four or five days going to the
union for the purpose of getting support for it, she knowing that such
neglect would be likely to produce the death of the child, it would
be manslaughter."
Erle, C. J. What became of the prisoner in that case ?
Carter. She was acquitted.
Erle, C. J. I should have been very much surprised, if any-
one had been convicted before me of felony in not applying to a
relieving officer for food.
Carter. Here the jury must be taken to have found that there
was a criminal neglect on the part of the mother. From the circum-
stances of the case there could not be a continued neglect for four or
five days as required in Regina v. Mabbett. In Regina v. Middle-
ship, 5 Cox C. C. 275, it was held that, if a woman has the means and
power of obtaining such assistance as may save the life of her child,
and neglects to do so, she is guilty of manslaughter. There the child
was newly born ; but the age is not material. If there is power to
obtain assistance, and a voluntary abstinence from doing so, it is
manslaughter. Then, does the duty cease to exist because the girl
is eighteen years of age? In Marriott's Case, 8 C. & P. 425, the
prisoner was convicted of manslaughter in neglecting to provide
necessaries for the use of an old woman who was in no way related
to him. So here the girl could not possibly procure assistance for
herself Futher it is contended that there was an implied contract
on the part of the mother to supply this girl with necessary assist-
ance in her labor. In Cheeseman's Case, 7 Car. & R, 455, there
was only the relationship of aunt and niece.
Wightman, J. That case is totally different. There was
actual violence.
Carter. In Ferguson's Case, i Lewin, 181, the prisoner, who
had undertaken to attend upon a woman in child-birth, was indicted
for neglecting to take proper care of her, by means whereof she
died, and was convicted of manslaughter. Here the prisoner under-
took to attend upon her daughter.
228^ Cases on Criminal Law.
Mellor, J. There is no evidence of that.
Carter. In Regina v. Walters, i Russ. C. & M., 488, 3d ed.,
CoLTMAN, J.,.says, " If a party so conducts himself with regard to
a human being, which is helpless and unable to provide for itself,
as must necessarily lead to its death, the crime amounts to murder."
So a gaoler maybe guilty of manslaughter, if he neglects to supply
his prisoner with neccessaries ; Rex v. Huggins, 2 Str., 882 ; S. C.
Ld. Raym., 1574. In Rex v. Simpson, i Lew., 172, it was held
that a man had no right to hazard the consequences in a case in
which medical assistance may be obtained, and that, if death
ensues by reason of his not obtaining such assistance, he is guilty
of manslaughter.
Erle, C. J. We have to see whether, on the facts stated to
us, there was an omission of any duty rendering the prisoner liable
to be convicted of felony. It is important that the boundaries of
crime should be well defined. They are not so definite as they
might be in cases of negligence ; and our duty is to consider and
see whether there are any facts here to bring this case within the
principle of any of the cases where the omission of a duty resulting
in death has been held to be manslaughter. The facts of the case
are that the. prisoner did not procure the aid of a midwife for her
daughter during child-birth. In consequence of her omitting to
do so, a difficulty occurred, and death ensued. Was there a breach
of duty for which she would be responsible in a criminal court in not
obtaining that aid ? We must take it that, if she had used ordinary
care, she would have procured the attendance of a midwife-; that
she knew where a midwife could be found ; and that, if the mid-
wife had been summoned, she would have attended. Of course
her skill must have been paid for ; and there is no evidence that
the woman had the means at her command of paying for that skill.
The midwife would probably have attended without being paid.
Yet the prisoner cannot be criminally responsible for not asking
for that aid which, perhaps, might have been given without
compensation. Aid of this kind is not always required in child-
birth ; and sometimes no ill consequences result from its absence.
Here, however, it was wanted, and was not applied. These facts
do not seem to me to fall within the principle of any of the cases
that have been cited. The cases where the person, whose death is
caused, has been brought into circumstances where he cannot help
Cases on Criminal Law. 229
himself, as by imprisonment, by the act of the party charged are
clearly distinguishable. There the persons imprisoned are helpless,
and their custodians, by the fact of their being so, have charged
themselves with the support of their prisoners. The case of parent
and child of tender years is also distinguishable, as are the other
cases where such a duty is imposed by law or contract, as in the
case of master and apprentice. Here the girl was beyond the age
of childhood, and was entirely emancipated. Then, being in the
prisoner's house, she is brought to bed, and the mother omits to
procure her a midwife. I cannot find any authority for saying that
that was such a breach of duty as renders her, in the event which
ensued, liable to the consequences of manslaughter.
Williams, J. I am of the same opinion and for the same
reasons. There was no legal duty binding the prisoner to procure
the aid of a midwife.
Williams, J. I am of the same opinion. No doubt, the
prisoner is morally guilty ; but legally she is not punishable.
Wilde, B., and Mellor, J., concurred.
Conviction quashed.
REGINA V. MARRIOTT.
Central Criminal Court, 1838.
8 Carrington &> Payne, 425.
Murder. The first count of the indictment stated that it was
the duty of the defendant to provide one Mary Warner, under the
care and control of the defendant, with sufficient meat, drink,
clothing, firing and medicine and, that by the neglect of the defend-
ant so to provide said Mary Warner with sufficient meat, etc., said
Mary Warner became mortally diseased, and of said mortal disease,
died. There was a second count charging that the defendant
wilfully, etc., assaulted Mary Warner, and confined her in a certain
dark, cold, unhealthy and unwholesome room,without proper food,
etc., by means of which she died.
From the evidence of the prosecution it appeared that the
deceased, Mrs. Warner, who was about 74 years of age, had lived
for some time with a sister in Cannon street, in the city, in a house
230 Cases on Criminal Law.
which they let out in lodgings, and of which the sister had a
lease under the Pewterers' Company. Upon the death of the sister
whose name was Reepe, in March, 1837, the prisoner attended at
the funeral, and, among others, a grandson of Mrs. Reepe, named
Charles Reepe, was present. He was called as a witness, and
gave his evidence as follows : — " Mrs. Warner's sister was my
grandfather's second wife ; I remember the death of Mrs. Reepe ;
I went to her funeral, and saw the prisoner there ; after the funeral
he called me on one side, and asked me if I should have any
objection to pay for my cloak, and my sister's, and my brother's
also, as he did not wish to put Mary Warner to any expense, and
he should pay for his. He told me he was left executor ; he
shewed me about a quarter of a sheet of writing paper as a will,
and told me he had found it by mere chance lying on the ground.
I observed Mrs. Warner was much grieved, and took a chair and
sat down by the side of her, and told her she should come and
live at home with me, and I would make her happy and comfort-
able for the remainder of her life ; her reply was, that it was a kind
offer, certainly. The prisoner said : " No, no, sir ; she shall go
home and live along with me, as you are no relation whatever." I
asked him what relation he was. He said he was a townsman,
and that he had buried Mrs. Reepe's sister, and it was Mrs. Reepe's
wish that he should bury her too ; in fact, that he was executor ;
he said : "Mrs. Warner is going home to live along with me until
affairs are settled, and I will make her happy and comfortable."
To prove the interference of the prisoner in Mrs. Warner's
affairs, as well as to show that he had undertaken to provide her
with food and other necessaries, a Mrs. Cruikshank was called as a
witness. She said : " I am the wife of Robert Cruikshank, and
live at No. 34 Cannon street, city; some day previous to the lOth
of October I went with my husband to No. i Dolphin court ; I
there saw the prisoner and his wife ; Mr. Marriott asked me to
write an agreement about the house No. 34 Cannon street, of which
Mr. Cruikshank was to take the upper part ; I heard the prisoner
mention the name of Mary Warner to his wife ; he talked in an in-
distinct tone ; I could hear nothing more than the name of Mary
Warner ; Mrs. Marriott dissented to what he said, whatever it was,
and he again repeated it to her, and she again dissented ; I asked
the prisoner what interest Mrs. Warner had in the house, and he
Cases on Criminal Law. 231
said, " None whatever " ; he asked me " If I remembered a con-
versation he had with me respecting the decease of Mrs. Reepe" ; I
told him " Perfectly well " ; he said, " Did I not remember he had
told me at Mrs. Reepe's decease, that Mrs. Warner was her sister;"
I inquired in what way Mrs. Warner could be a party to the agree-
ment ; his reply was, " None whatever." He said something about
her not being capable of undergoing the fatigue ; that at her
advanced age she was quite incapable ; that he had been accus-
tomed to let lodgings ; there was an agreement ultimately signed ;
I produce it; it is not stamped; after it had been signed, I
inquired whether Mrs. Warner was a relative, as he seemed to
take such an interest in her affairs; he said, "None at all" ; he
said, respecting the house in Cannon street, Mrs. Warner having
been accustomed to let lodgings, he had taken the lease of the
house of the Pewterers' Company, on condition of paying up an
arrear of rent ; that they had given him four years to pay it by
three instalments, 20/. of which he had paid, in consideration of
which he had undertaken to keep Mrs. Warner comfortable as long
as she lived ; I wished to purchase some of the furniture, and he
said I might make my own selection ; he did not say to whom it
belonged ; I understood it was his own property ; he did not speak
of it as anybody's property but his own ; he appointed a Mr. Kelly
to value the furniture in the house in Cannon street to Mr. Cruik-
shank, and a Mr. Phillips was appointed to value it for us ; the
amount of the valuation was 37/., within a few shillings ; that has
not been paid ; we were to pay it to Mr. Marriott. On her cross-
examination she said : — " When the name of Mary Warner was
mentioned, and Mrs. Marriott shook her head, the prisoner said,
' Yes, yesj better ; ' and the name of Mary Warner was put into the
agreement, because Mrs. Marriott asked me to do so."
The clerk to the Pewterers' Company was called, and he said
" there was never any premises in Cannon street let to the
prisoner ; he never at any time took a lease in any shape from the
Pewterers' Company ; he has paid two instalments of il/. i$s. each
for arrears of rent due from Mrs. Reepe ; he paid it as her execu-
tor, he so stated." On his cross-examination he was asked whether
there was not a petition sent in on the part of Mary Warner, as
the sister of Mrs. Reepe, to let her off the arrears in consideration
of her long tenancy? His reply was : "There was a memorial sent
232 Cases on Criminal Law.
in in the name of the prisoner ; he stated his object to be to serve
Mary Warner ; the prayer of the petition was not acceded to ; he
made himself answerable for the amount, and signed a written
memorandum." The will of Mrs. Reepe was read ; it was dated
the 26th of March, 1836, bequeathing to Mrs. Warner all her
effects, and the lease of the house in Cannon street. A clerk in the
Prerogative Office was called, and stated that the personal property
was sworn under 100/., and that letters of administration were
granted the 20th of July, 1837; that Mrs. Warner must have
appeared personally ; and that the prisoner was one of her sureties
for the proper administration of the effects.'
Patteson, J., in summing up (after stating the first count of
the indictment and observing upon certain parts of the evidence)
said : If the prisoner was guilty of wilful neglect, so gross and
wilful that you are satisfied he must have contemplated the death
of Mrs. Warner, then he will be guilty of murder. If, however, you
think only that he was so careless, that her death was occasioned
by his neghgence, though he did not contemplate it, he will be
guilty of manslaughter. The cases which have happened of this
description have been generally cases of children and servants,
where the duty has been apparent. This is not such a case ; but
it will be for you to say, whether from the way in which the
prisoner treated her, he had not by way of contract, in some way
or other, taken upon him the performance of that duty which she,
from age and infirmity, was incapable of doing. [His Lordship
then read the statements of Mr. Reepe and Mrs. Cruikshank, and
continued] This is the evidence on which you are called on to
infer that the prisoner undertook to provide the deceased with
necessaries ; and though, if he broke that contract, he might not be
liable to be indicted during her life, yet, if by his negligence her
death was occasioned, then he becomes criminally responsible.
Verdict. Guilty of manslaughter only.
^ The statemement is abridged and a portion of the evidence not bear-
ing on the duty of the defendant is omitted.
Cases ON Criminal Law. 233
REGINA V. POCOCK.
Queens Bench, 1851.
5 Cox C. C, 172.
This was a rule to quash a coroner's inquisition which had
been removed into this court by certiorari. The inquisition alleged
that the defendants were the trustees of a public road under an act
of Parliament ; that it was their duty to contract for the due
reparation of the said road ; that they feloniously did neglect and
omit to contract for the repair of the same, whereby it became very
miry, ruinous, deep, broken, and in great decay ; and that a cart,
which the deceased was driving along the road, fell into a hole in
the road, and by reason thereof the deceased was thrown out, and
sustained the injuries of which he afterwards died.
Charnock showed cause. This case is not distinguishable from
those of persons who have the charge of machinery at mines, of
signals, or locomotives on railways, and the like ; and there are
many precedents of indictments for manslaughter in such cases
where death has been occasioned by a neglect of duty on the part
of the persons so intrusted ; R. v. Barrett, 2 Car. & K. 343 ; R.
V. Haines, ib., 368 ; R. v. Gregory, S B. & Ad. 555. Here a pub-
Uc duty was cast upon the trustees, and they were authorized to
raise money by rates for the purpose ; and if their neglect of duty
has caused the death of another, they are guilty of manslaughter.
Hayes, contra, was not called upon.
Lord Campbell, C. J. The cases cited show a personal duty,
the neglect of which has directly caused death ; and, no doubt,
where that is the case, a conviction of manslaughter is right. But
how do those apply to trustees of a highway? How can it be said
that their omission to raise a rate, or to contract for the reparation
of the road, directly causes the death ? If so, the surveyors or the
inhabitants of the parish would be equally guilty of manslaughter ;
for the law casts upon them the duty of keeping the roads in
repair. To uphold this inquisition would be to extend the crim-
inal law in a most alarming manner, for which there is no principle
or precedent.
Patteson, J. This is really too extravagant.
WiGHTMAN, J. Concurred.
234 Cases on Criminal Law.
Erle, J. In all the cases of indictment for manslaughter,
where the death has been occasioned by omission to discharge a
duty, it will be found that the duty was one connected with life, so
that the ordinary consequence of neglecting it would be death.
Such are the cases of machinery at mines, of engine-drivers, or the
omission to supply food to helpless infants.
Inquisition quashed.
UNITED STATES v. MOORE.
United States District Court for District of Massachu-
setts, 1873.
2 Lowell, 232.
Indictment. — False Swearing. — The jury found the defend-
ant guilty on the second count ; ^ and he moved for a new trial
upon several rulings, which had been duly reserved, but are not
necessary to be here referred to, and upon one part of the charge,
which is recited in the opinion of the court.
Lowell, J. I have made up my mind that my instruction to
the jury upon one point was not sufficiently full and explicit, and
may, perhaps, have misled them, to the injury of the defendant. I
charged in the words attributed to Judge Sprague, in U. S. v.
Atkins, I Sprague, 558, "that the jury must be satisfied that the
defendant swore to a declaration which, at the time, he knew to
be false ; and that may be either by swearing to a fact which he
knows is not true, or by swearing to his knowledge of the fact
when he knew he had no such knowledge.''
There is some difference of opinion in the United States as to
whether perjury, or false swearing in the nature of perjury, can be
committed by mere rash and reckless statements on oath ; and
though my charge, rightly understood, did not authorize the jury
to convict the defendant, if the evidence only showed recklessness,
yet I am not sure it may not have been understood in that sense.
Indeed, I think my own views were not quite distinct upon the
point. Mr. Bishop, in his treatise on Criminal Law (3d ed.) vol. i,
^ Part of this case is omitted.
Cases on Criminal Law. 235
§ 396, says : " Probably the better opinion is, that perjury is not
committed by any mere reckless swearing to what the witness
would, if more cautious, learn to be false ; but the oath must be
wilfully corrupt." In a note, he quotes, as opposed to his own
opinion, an extract from a report of the penal code commissioners
of New York : " An unqualified statement of what one does not
know to be true is equivalent to a statement of that which one
believes to be false." The latter proposition may be nearly true,
so far as the effect of the statement on others is concerned ; but it
is not a sound legal definition of perjury. I agree, rather, with Mr.
Bishop's opinion, that there must be some fact falsely stated, with
knowledge of its falsity, before there can be perjury. It has been
held, indeed, by an able and learned court, that rash swearing,
without any reasonable or probablecauseof belief of the fact sworn
to, is perjury : Com. v. Cornish, 6 Binney, 249. That was a case
in which the defendant had been wounded in a riot, at night, and
had sworn to the prosecutor as the person who wounded him. The
doctrine was denied to be law, in an able and careful charge to the
jury in the. Circuit Court of the United States, sitting in the same
State : U. S. v. Shellmire, Baldwin, 370. It has been virtually
denied in this State, in Com. v. Brady, 5 Gray, 78, where the
defendant swore that he saw a man running from a burning build-
ing, whom he believed to be A. The judge charged in, the lan-
guage of the court in Pennsylvania, and the ruling was set aside.
The court, to be sure, put their decision upon the ground that the
defendant only swore to his belief; but personal identity is almost
always a matter of belief An affidavit or statement, that I saw a
certain person, does not usually import anything more than that I
saw some one whom I believed, and still believe, to be that person.
If I saw no one, or if I believed the person to be different from him
I have named, it is perjury ; but not otherwise. If any material
circumstance is falsely stated, such as that the witness was present,
and heard a certain conversation, it has been held to be perjury if
he were not present, though the conversation really occurred : Peo-
ple V. McKinney, 3 Parker, Crim. C, 510. In such a case, the
materiality of the circumstance would be the only question. Grant-
ing the materiality of the fact, whether it be a statement of knowl-
edge, or of information or belief, or a simple statement of a fact, if
the witness knows that the fact is not so, or that he has no such
236 Cases on Criminal Law.
information, or no such belief, he is guilty. But if he only swears
rashly to his belief of a matter of which he does not profess to have
personal knowledge, the jury cannot be permitted to decide on the
reasonableness of his belief, except as tending to show whether he
did believe. In short, perjury is always of some matter of fact ;
and belief may be a fact. In this case, the only questions of fact put
in issue by the indictment and by the law are : Was the statement
false, and did the defendant know it to be false? In this respect,
it is like the offence of passing a counterfeit note, knowing it to be
counterfeit. Proof of reasonable cause of behef may warrant a jury
to find knowledge ; but it is not the legal equivalent of knowledge.
The true question, therefore, for the jury was the one which
the indictment points out : Did the defendant swear to this fact,
knowing it to be false ? I do not mean to say that there was not
evidence from which the jury might have answered this question
in the affirmative ; but, as I cannot say how they would have
answered it, I feel it to be my duty to grant a new trial.
New trial ordered.
Cases on Criminal Law.
237
Chapter V.
Intent as Affected by Conditions.
SECTION I.
IGNORANCE OR MISTAKE OF LAW.
REX V. THURSTON.
King's Bench, 1649.
I Levinz, 91.
Indictment of murder, and on a special verdict found at the
Assizes at Bury, the case was : in Hillary Term, 1659, ^ latitat
issued to arrest him, returnable in Easter Term, 1660, on which
the twenty-ninth of May he was arrested by a warrant thereupon,
and upon that arrest the bailiff was killed ; and afterwards an act
is made for the confirmation of all judicial proceedings, which
related to the first day of the parliament, viz., 15 April, 1660, and
the sole question was, if by the relation of the act which made the
proceedings legal and the arrest good (which else had been void
and without authority), this killing be murder. And it was argued
at the bar by Kelynge, for the King, and by Jones, for the defendant :
And Kelynge said, that by relation all the process is made good,
for it shall relate to the first day of the parliament; /(?«fj argued the
Act should relate to the first day of the parliament, but not to such
intent as to make it murther ex post facto, which was not so when
the fact was done. The Court said nothing; but afterwards, in
Easter Term, 16 Car. 2, I heard Thurston plead his pardon of this
murder, whereby it seems as if the opinion of the Court was against
him.
238 Cases on Criminal Law.
STATE V. BOYETT.
Supreme Court of North Carolina, 1849.
10 Iredell, 336.
Pearson, J.^ " Ignorantia legis neminem excusat." Every
one competent to act for hiniself is presumed to know the law.
No one is allowed to excuse himself by pleading ignorance. Courts
are compelled to act upon this rule, as well in criminal as civil
matters. It lies at the foundation of the administration of justice.
And there is no telling to what extent, if admissible, the plea of
ignorance would be carried, or the degree of embarrassment that
would be introduced into every trial, by conflicting evidence upon
the question of ignorance.
In civil matters, it is admitted, the presumption is frequently
not in accordance with the truth. The sales of property are com-
plicated systems — the result " not of the reason of any one man,
but of many men put together ; " hence, they are not often under-
stood, and more frequently not properly applied, and the presump-
tion can only be justified upon the ground of necessity. But, in
criminal matters, the presumption most usually accords with the
truth. As to such as are. mala in se, every one has an innate sense
of right and wrong, which enables him to know when he violates
the law, and it is. of no consequence if he be not able to give the
name, by which the offence is known in the law books, or to point
out the nice distinctions between the different grades of offence.
As to such as are " mala prohibita" they depend upon statutes
printed and published and put within the reach of every one ; so
that no one has a right to complain if a presumption, necessary
to the administration of the law, is applied to him. To allow
ignorance as an excuse would be to offer a reward to the
ignorant.
The defendant voted, when he was not entitled by law to vote.
He is presumed to know the law. Hence, he voted, knowing
that he had no right, and, acting with this knowledge, he neces-
sarily committed a fraud upon the public — in the words of the Act
' The opinion only is printed.
Cases on Criminal Law. 239
he knowingly and fraudulently voted when he was not entitled
to vote. It being proved on the part of the State that he
voted, not having resided within the bounds of the company for
six months next preceding the election, a case was made out
against him.
He offered to prove, for the purpose of rebutting the
inference of fraud, that he had stated the facts to a respect-
able gentleman, who advised him he had a right to vote.
His Honor held the testimony inadmissible. We concur in that
opinion.
The evidence had no tendency to rebut the inference of
fraud, for the inference was made from his presumed knowledge, of
the law, and that presumption could not be met by any such proof,
without introducing all the evils which the rule was intended to
avoid. The question, in effect, was : shall a man be allowed, in
excuse of a violation of the law, to prove that he was ignorant of
the very law, under which he professed to act, and under which he
claimed the privilege of voting ? If he was not ignorant of the
law, and that he cannot be heard to allege, then, he voted knowingly,
and, by necessary inference, fraudulently.
An indictment for extortion charges that the defendant
received the fee " unlawfully, corruptly, deceitfully, and extorsively. "
This averment the State must prove. It is done by showing that
the defendant received what the law does not allow him to take ;
for the presumption is " he knew the law upon the subject of fees
to be taken by himself," and the inference from such knowledge is,
that he acted "corruptly and deceitfully," (words quite as strong
as knowingly and fraudulently), unless it is shown that he did so
by some inadvertence, or mistake in calculation. He cannot
excuse himself for taking more than the legal fee by saying that
he was misled by the advice of an attorney. If such, or like
excuses were admitted, it would hardly ever be possible to convict.
He might always contrive to ground his conduct upon misappre-
hension or improper advice. State v. Dickens, i Hay, 406. It
would be a different question if the defendant had stated the
facts to the judges of the election, and they had decided in
favor of his right to vote, for their decision would rebut the
presumption of knowledge on his part, in a manner contemplated
by law.
240 Cases on Criminal Law.
The case was ably argued for the defendant. It was insisted
that it was necessary for the State to aver and prove that the
defendant voted knowingly and fraudulently. That position is
admitted. The reply is, the averment was made and was
proved ; for proof being made that he voted when he was not
entitled to vote, the presumption is that he knew the law, and
fraud is the necessary inference, as corruption and deceit were in
the case above cited. It cannot be contended, that to fix him
with knowledge, the State must show that some one read and
explained the law to him ; or to fix him with fraud, that it must be
proven he had been bribed. If so, the statute is a dead letter.
Our attention was called to the fact that the Act of , 1 844, making
the offence indictable, uses the words, " knowingly and fraudu-
lently," which words are not used in the Act of 1777, imposing a
penalty. To incur the penalty under the Act of 1777, the voting
must be unlawful, and it must be done knowingly and fraudu-
lently, in the sense above explained. If one, having a deed for
fifty acres of land, votes in the Senate, and it turns out that the
deed only contains forty-nine acres, the penalty is not incurred,
unless he knew the fact at the time he voted. So, if one votes for
a constable, and it turns out that the dividing line includes him in
another company, there is not in either case that criminal intent,
which is a necessary ingredient of the offence, whether it be pun-
ished by a penalty or by indictment. The Act of 1844 expresses
in so many words what the law would have implied. It is a
strained inference, that, by so doing, the Legislature intended to
make the case of illegal voting an " exception," and to take it out
of the rule "ignorantia legis'' a rule which has always been
acted upon in our law, and in the laws of every nation of which
we have any knowledge, and without which, in fact, the law cannot
be administered. The inference sought to be made results in this :
the Legislature did not intend the Act of 1844 to be carried into
effect; it was intended to he " brutum fulmen." No reason has
been suggested for making an exception in this case. The only
additional qualification, to that of a voter for a member of the
House of Commons, is a residence of six months in the captain's
company.
This is not complicated or difficult to be understood. Why
make the exception and offer a reward for ignorance in this partic-
Cases on Criminal Law. 241
ular case ? Such a construction cannot be admitted, unless the
law makers had declared their intention by positive enactment.
Per Curiam. There is no error in the Court below, and the
same must be so certified.^
CUTLER V. STATE.
Supreme Court of New Jersey, 1873.
36 New Jersey Law, 1 25.
The opinion of the Court was delivered by Beasley, C. J.^
The defendant was indicted for extortion in taking fees to which
he was not entitled, on a criminal complaint before him as a justice
of the peace, The defence which he set up, and which was over-
ruled, was that he had taken these moneys innocently, and under a
belief that by force of the statute he had a right to exact them.
This subject is regulated by the twenty-eighth section of the
act for the punishment of crimes. Nix. Dig. 197. This clause
declares that no justice or other officer of this State shall receive,
or take any fee or reward, to execute and do his duty and office,
but such as is or shall be allowed by the laws of this State, and
that "if any justice, etc., shall receive or take, by color of his
office any fee or reward whatsoever, not allowed by the laws of this'
State, for doing his office, and be thereof convicted, he shall be
punished," etc.
If the magistrate received the fees in question without any
corrupt intent, and under the conviction that they were lawfully his
due, I do not think such an act was a crime by force of the statute
above cited.
^Accord: Illegal voting, McGuire v. St., 7 Humph., 54 (1846);
keeping gaming house, Winehart v. St., 6 Ind., 30 (1854) ; statutory larceny,
St. V. Welch, 73 Mo., 284 (1880); bigamy, P. -v. Weed, 36 N. Y., 628
(1883); murder, Weston v. C, lii Pa., 251 (1886) ; opening grave, St. v.
McLean, 121 N. C, 589 (1897); unlawful discrimination, St v. Railway,
122 N. C, 1052 (1898); compounding crime, St. v. Carver, 69 N, H., 216
(1897) ; false imprisonment, Begley v. C, 60 S. W. (Ky.) 847 (1901); cf. C.
V. Bradford, 9 Mete, 268 (1845).— Ed.
2 Part of the opinion relating to another point is omitted.
242 Cases on Criminal Law.
But it is argued on the part of the prosecution, that as the fees
to which the justice was entitled are fixed by law, and as he cannot
set up, as an excuse for his conduct his ignorance of the law, his
guilty knowledge is undeniable. The argument goes upon the
legal maxim ignorantia legis neminem excusat. But this rule, in
its application to the law of crimes, is subject, as it is sometimes
in respect to civil rights, to certain important exceptions. Where
the act done is malum in se, or where the law which has been
infringed was settled and plain, the maxim, in its rigor, will be
applied ; but where the law is not settled, or is obscure, and
where the guilty intention, being a necessary constituent of the
particular offence, is dependent on a knowledge of the law, this
rule, if enforced, would be misappHed. To give it any force in such
instances, would be to turn it aside from its rational and original
purpose, and to convert it into an instrument of injustice. The judg-
ments of the Courts have confined it to its proper sphere. When-
ever a special mental condition constitutes a part of the offence
charged, and such condition depends on the question whether
or not the culprit had certain knowledge with respect to matters
of law, in every such case it has been declared that the subject of
the existence of such knowledge is open to inquiry, as a fact to be
found by the jury. This doctrine has often been applied to the
offence of larceny. The criminal intent, which is an essential part
of that crime, involves a knowledge that the property taken belongs
to another ; but even when all the facts are known to the accused,
and so the right to the property is a mere question of law, still he
will make good his defence if he can show, in a satisfactory man-
ner, that being under a misapprehension as to his legal rights, he
honestly believed the articles in question to be his own. Rex v.
Hall, 3. Car. & P., 409 ; Reg. v. Reed, Car. & Marsh. 306.
The adjudications show many other applications of the same
principle, and the facts of some of such cases were not substantially
dissimilar from those embraced in the present inquiry. In the case
of The People v. Whaley, 6 Cow., 661, a justice of the peace had
been indicted for taking illegal fees, and the Court held that the
motives of the defendant, whether they showed corruption or that
he acted through a mistake of the law, were a proper question for
a jury. The case of The Commonwealth v. Shed, i Mass., 228,
was put before the jury on the same ground. This was likewise
Cases on Criminal Law. 243
the ground of decision in the case of The Commonwealth v.
Bradford, 9 Mete, 268, the charge being for illegal voting, and it
being declared that evidence that the defendant had consulted
counsel as to his right of suffrage and had acted on the advice thus
obtained, was admissible in his favor. This evidence was only
important to show that the defendant in infringing the statute had
done so in ignorance of the rule of law upon the subject. Many-
other cases resting on the same basis might be cited ; but the fore-
going are sufficient to mark clearly the boundaries delineated by
the courts to the general rule, that ignorance of law is no defence
when the mandates of a statute have been disregarded or a crime
has been perpetrated. That the present case falls within the excep-
tions to this general rule, appears to me to be plain. There
can be no doubt that an opinion very generally prevailed that mag-
istrates had the right to exact the fees which were received by this
defendant, and that they could be legally taken under similar cir-
cumstances. The prevalence of such an opinion could not, it is
true, legalize the act of taking such fees ; but its existence might
tend to show that the defendant, when he did the act with which
he stands charged, was not conscious of doing anything wrong.
If a justice of the peace, being called upon to construe a
statute with respect to the fees coming to himself, should, exercising
due care, form an honest judgment as to his dues, and should act
upon such judgment, it would seem palpably unjust, and therefore
inconsistent with the ordinary grounds of judicial action, to hold
such conduct criminal if it should happen that a higher tribunal
should dissent from the view thus taken, and should decide that the
statute was not susceptible of the interpretation put upon it. I
think the defendant had the right in this case to" prove to the jury
that the moneys, which it is charged he took extorsively, were
received by him under a mistake as to his legal rights, and that as
such evidence being offered by him was overruled, the judgment
on that account must be reversed.^
1 Accord: Perjury, U. S. v. Conner, 3 McLean, 573 (1845); malicious
mischief, Goforth v. St., 8 Humph., 37 (1847) ; trespass, St. w. Hause, 71 N.
C, 518 (1874); conspiracy, P. v. Powell, 63, N. Y., 88 (1875); larceny, P.
V. Husband, 36 Mich., 306 (1877) ; extortion, Leeman v. St, 35 Ark., 438
(1880). See also Reg. v. Allday, 8 Car. & P., 136 (1837).— Ed,
^44 Cases on Criminal Law.
SECTION II.
IGNORANCE OR MISTAKE OF FACT.
In the case of Sir William Hawksworth, related by Baker in
his chronicle of the time of Edward IV., p. 223 ^sud anno, 147 1],
he being weary of his life and willing to be rid of it by another's
hand, blamed his parker for suffeHng his deer to be destroyed, and
commanded him that he should shoot the next man that he met in
the park that would not stand or speak. The knight himself came
in the night into the park, and, being mfet by the keeper, refused to
stand or speak. The keeper shot and killed him, not knowing
him to be his master. This seems to be no felony, but excusable
by the statute of Malef adores in parcis, for the keeper was in no
fault, but his master ; but, had he known him, it had been murder.
/ Hale, P. C, 4.0.
COMMONWEALTH v. PRESBY.
Supreme Judicial Court of Massachusetts, 1859.
80 Massachusetts, 65.
Indictment for an assault and battery. Trial in the Court of
Common Pleas, in Middlesex, at October Term, 1858, before
Aiken, J., to whose rulings the defendant alleged exceptions, the
material part of which is stated in the opinion of the Court. The
decision was made in i860.
Hoar, J. The defendant, a police officer, and watchman
of the city of Lowell, arrested one Harford for being intox-
icated in the public street in .that city in the night time, and
committed him to the watch house. For this act he was indicted
for an assault and battery upon Harford ; and at the trial the
presiding judge was asked to instruct the jury, "that, if said
Presby had reasonable and probable cause to believe that said
Harford was intoxicated at the time of the arrest, then he was
authorized in taking and retaining said Harford." But the judge
Cases on Criminal Law. 245.
refused so to rule, and instructed the jury that if Harford was .not
intoxicated, they should find the defendant guilty ; to which refusal
and instruction exceptions were taken. The duty and power of a
police officer to make an arrest without a warrant, for the offence
of intoxication, arise from the Statute of 1855, c. 215, § 23, which
provides that " if any person shall be found in a state of intoxica-
tion, in any highway, street, or other public place, any sheriff,
deputy sheriff, constable, watchman or police officer, shall, without
any warrant, take such person into custody, and detain him in some
proper place, until, in the opinion of such officer, he shall be so far
recovered from his intoxication as to render it proper to carry him
before a court of justice," &c.
It is argued on behalf of the Commonwealth that if Harford
was not intoxicated, this statute affords no justification for his arrest,
because the fact, and not a suspicion or belief, however reasonable,
of intoxication, is requisite to justification. This may be true in
regard to the civil rights of the person whose liberty is invaded ;
and in a civil action the wrong-doer must usually justify his act, or
be held responsible for the damages which it has occasioned. And
it may be conceded that if the defendant had no other defence:to
this indictment than a justification of the act, his defence fails.
We come then to the consideration of the question, whether
it is true, as a universal proposition, that every imprisonment, arrest
or detention of the person, which is not capable, of a technical
justification, constitutes a criminal assault and battery. However
loosely the doctrine may have been stated in elementary books, it
is evident, upon careful consideration that this cannot be so; and
we are aware of no adjudged case in which it has been so deter-
mined.
To constitute a criminal act, there must be, as a general rule,
a criminal intent. "An unwarrantable act," says Blackstone,
'' without a vicious will, is no crime at all." 4 Bl. Com. 21.
"Ignorance or mistake is a defect of will ; when a man, intending
to do a lawful act, does that which is unlawful. For here the deed
and the will acting separately, there is notthat conjunction between
them, which is necessary to form a criminal act. But this must be
an ignorance or mistake of fact, and not an error in point of law."
4 Bl. Com. 27. This principle is recognized by all the best author-
ities on, criminal law. Thus in i Russell On, Crimes,;(7th Amer.
246 Cases on Criminal Law.
ed.) I, it is said that "without the consent of the will, human
actions cannot be considered as culpable ; nor where there is no
will to commit an offence, is there any just reason why a party
should incur the penalties of a law made for the punishment of
crimes and offences." And in I Hale's Pleas of the Crown, 15, the
general doctrine is stated, that "where there is no will to commit
an offence, there can be no transgression." See also i Gabbett
Crim. Law, 4. And in all these writers, ignorance of fact, unac-
companied by any criminal negligence, is enumerated as one of the
causes of exemption from criminal responsibility.
As an application of the rule, Levett's case, cited by Justice
Jones in Cro. Car. 538, is most often quoted. In that case, upon
an alarm of thieves in the night time, the master of the house killed
a person found secreted in a closet, who was not a thief, but was
there by lawful means ; but the act having been done under the
reasonable belief that the person killed was a felon, the excuse was
held sufficient. And Hale gives the illustration of a sentinel firing
at his commanding officer, who advances to his post, under the
reasonable belief that he is an enemy, as coming within the same
rule. I Hale, P. C, 42.
The principle is applied directly to the case of assaults, in i
Russell on Crimes, 754. "Whether the act shall amount to an assault
must in every case, be collected from the intention." And it has
been said by this court, that " it is undoubtedly true, that in order
to support an indictment for an assault and battery, it is necessary
to show that it was committed ex intentione, and that if the criminal
intent is wanting, the offence is not made out." Commonwealth v.
Randall, 4 Gray, 38. The court indeed add that " this intent is
always inferred from the unlawful act," but by an unlawful act is
meant intentional violence, without justification or excuse; and
where ignorance of fact is an excuse, the inference is rebutted.
Insanity or idiocy has always been held an excuse for an act other-
wise criminal, because there is no criminal intent accompanying the
act.
There may be in many cases some difficulty in applying these
familiar principles to the facts proved ; and great caution should cer-
tainly be used in admitting the excuse of ignorance or mistake, so as
to exclude from its protection those who do not exercise all reason-
able means to inform themselves before they commit an act which
Cases on Criminal Law, 247
is apparently an invasion of private right, and a breach of the public
peace ; and not to sanction violence under circumstances where
there is no necessity for any action whatever.
But in the case we are now considering, the duty is made im-
perative upon the officer to make the arrest without a warrant, if he
finds an intoxicated person in the street. The language of
the statute is not that he " may," but that he " shall " arrest
the offender. If he neglects this duty, he is liable to an in-
dictment. He has then this alternative presented, that if the person
whom he sees is really intoxicated, he must arrest him, or suffer
the consequences of official misconduct. The fact of intoxication,
though usually easy to ascertain, is not a fact capable of demon-
stration, or of ascertainment with absolute certainty, in most cases.
Suppose a watchman to find a man in the gutter, stupefied, and
smelling very strongly of spirituous liquors. The man may have
fallen in a fit, and some person have tried to relieve him by the
application of a stimulant, and then have left him in search of
assistance. Or, in another case, the person arrested may have been
simulating, for purposes of amusement or mischief, the appearance
and conduct of drunkenness. Is the officer to be held a criminal,
if, using his best judgment and discretion, and all the means of in-
formation in his power, in a case where he is called upon to act,
he makes a mistake of fact, and comes to a wrong conclusion ? It
would be singular, indeed, if a man deficient in reason would be
protected from criminal responsibility; and another, who was obliged
to decide upon the evidence before him, and used in good faith all
the reason and faculties which he had, should be held guilty.
Upon the exceptions before us, we therefore feel bound to
decide, that the defendant, being required by his official duty to
make the arrest, if the fact of intoxication existed ; and acting in a
matter which did not admit of absolute certainty ; if he acted in
good faith, upon reasonable and probable cause of belief, without
rashness or negligence, he is not to be regarded as a criminal
because he is found to have been mistaken ; and that the excep-
tions must be sustained, and a new trial granted.
R, B. Caverly, for the defendant.
6". H. Phillips (Attorney General), for the Commonwealth,
cited St. 1855, t. 215, § 23 ; Rohan v. Swain, 5, Cush., 281.
248 Cases on Criminal Law.
STATE V. NASH.
Supreme Court of North Carolina, 1883.
88 North Carolina, 618.
Indictment for assault and battery, tried at the Fall Term, 1882,
of Richmond Superior Court, before Gilmer, J.
The defendant was put upon the stand as a witness in his own
behalf; admitted that he fired the gun at the crowd, and proposed
to prove that before he fired, his child, who was sleeping near a
.window in the house, through which the noise of the bells and horns
and firing was heard and the flash of the firing seen, rose up and
■ran to the witness with blood on her face (caused as he afterwards
learned, but did not then know, by her running against the end of
a table), and under the impulse of the moment, believing that she
had been shot, he got his gun and went to the door, and, seeing,
the flash of pistols fired, as he supposed, by the retreating crowd,
'fired his gun at and into the crowd. This evidence was objected
to by the state and excluded by the court, and the defendant
excepted.
The court instructed the jury that the defendant had not shown
justification for the shooting. Verdict of guilty ; judgment ; appeal
by the defendant'
Ashe, J. fhe question presented by the record is, was there
error in the refusal of the judge to receive the evidence offered by
the defendant ? We are of the opinion there was error in rejecting
so much of the proposed testimony as tended to show, on the part
of the defendant, a reasonable ground of belief that the trespassers
upon his premises had fired into his house and wounded his child.
It may be, as testified by the prosecutor, that the band of
young men who went to the defendant's house on the night in ques-
tion only intended innocent amusement ; but there is one unusual
and rather extraordinary feature in the transaction, that the party
intending a mere serenade should, on such an occasion, carry guns
and pistols ; they are certainly very unusual instruments of music
in the hands even of a calithumpian band.
They I entered the enclosure, twenty in numb(jr ; marched
1 The statement of facts is abridged.
Cases on Criminal Law. 249
round the house, blowing horns, ringing bells and firing guns and
pistols, which must have greatly frightened the family and the
defendant himself, unless he is a man of more than ordinary cour-
age. But whether awed or not by such a display of numbers and
lawlessness, yielding to the dictates of prudence, he submitted to
the humiliating indignity and remained within doors until his httle
daughter, as he proposed to show, ran to him with her face bleed-
ing ; and believing, as was natural under the circumstances, that she
had been shot, he seized his gun and went to the door, saw the
flash of firearms and shot into the crowd and wounded the prose-
cutor. We must suppose it was all the work of an instant. Did
the defendant, under these circumstances, have reasonable ground
to believe that his daughter had been shot^ and the assault upon
him and his house was continuing ? If he had, then he ought to
have been acquitted.
We know this has been a much mooted question, but upon
an investigation of the authorities our conclusion is, that a reasonable
belief that a felony is in the act of being committed on one will
excuse the killing of the supposed assailant, though no felony was
in fact intended. And whatever will excuse homicide, will, of
course, excuse assault and battery.
In State v. Scott, 4 Ired., 409, the court says : " In consulta-
tion it seemed to us at one time that the case might properly have
been left to the jury, favorably to the prisoner, on the principle of
Levet's case, Cro. Car., 538 ; i Hale, 474, which is, that if the pris-
oner had reasonable ground for believing that the deceased intended
to kill him, and under that belief slew him, it would be excusable,
or, at most, only manslaughter, though in truth the deceased had no
such design at the time." It is to be noted that Levet was acquitted.
But the court did not give the prisoner, in Scott's case, the benefit
of the principle, for the reason that no such instruction had been
asked in the court below, the court concluding , that the prisoner
would have requested the instruction, if he had acted upon such
belief ; and there were besides other circumstances in the case
which prevented the application of the principle. But it is clearly
to be deduced from the opinion of Chief Justice Ruffin, who
spoke for the court, that in a proper case the principle might be
invoked to excuse a defendant. See also Patterson v. People, 46
Barb , 627.
250 Cases on Criminal Law.
The same doctrine was enunciated by Parker, J., afterwards
Chief Justice of the Supreme Court of Massachusetts, in the famous
case of Commonwealth v. Selfridge, Self. Trial, 100, and the prin-
ciple is thus illustrated : " A, in the peaceful pursuit of his affairs,
sees B walking towards him with an outstretched arm and a pistol
in his hand, and using violent menaces against his life as he
advances. Having approached near enough in the same attitude,
A, who has a club in his hand, strikes B over the head before or at
the same instant the pistol is fired, and of the wound B dies. It
turned out that the pistol was in fact loaded with powder only and
that the real design of B was only to terrify A." The judge
inquired : " Will any reasonable man say that A is more criminal
than he would have been if there had been a ball in the pistol ? "
2 Whar. Crim. Law, § 1026 (g) and note ; Whar. Law of Homi-
cide, 215, et seq.
But it may be objected that the defendant acted too rashly ;
before he resorted to the use of his gun, he should have taken the
precaution to ascertain the fact whether his child had been actually
shot. But that doctrine is inconsistent with the principle we have
announced. If the defendant had reason to believe and did believe
in the danger, he had the right to act as though the danger really
existed and was imminent. Taking, then, the fact to be that the
trespassers had fired into the defendant's house and shot his child,
and the firing continued, there was no time for delay. The occa-
sion required prompt action. The next shot might strike him or
some other member of his family. Under these circumstances the
law would justify the defendant in firing upon his assailants in
defense of himself and his family.
But as we have said, the grounds of belief must be reasonable.
The defendant must judge, at the time, of the ground of his appre-
hension, and he must judge at his peril ; for it is the province of the
jury on the trial to determine the reasonable ground of his belief.
And here the error is in the court's refusing to receive the proposed
evidence, and submitting that question to the consideration of the
jury. A venire de novo must be awarded.*
Smith, C. J., dissenting. I am unable to concur with the
1 Accord : Reg. v. Rose, 15 Cox C. C, 540 (1884) ; Cf. Isham v. St.
supra; St. V. Downs, 91 Mo., 19 (1886). — Ed.
Cases on Criminal Law. 251
other members of the court in the conclusion reached that the tes-
timony of the defendant in explanation of his conduct, if admitted
and believed, would be a defense to the charge, or have any other
legal effect than to mitigate his offence ; and hence, as immaterial
upon the issue, and tending to mislead, there is no error in reject-
ing it.
The facts in connection with this proposed statement are sum-
marily as follows : A boisterous and unruly crowd, in what seems
to have been a frolic, enter the defendant's premises in the early
night with bells, horns and firearms, by the noise of which as they
pass around his dwelling himself and his family are greatly annoyed
and their peace disturbed. As they are about to leave, his little
frightened daughter runs up to him with blood upon her face,
caused by her striking against a table, but which he then supposed
to proceed from a shot wound. Acting upon the impulse produced
by this misconception and without stopping to make inquiry as to the
cause or extent of the inquiry [injury?], he seizes his gun loaded
with shot of large size, hastens to the door and out into the porch,
and, seeing the flash of the gun, fires into the retreating body then
near the outer gate, some thirty-five yards distant, without a word of
warning or remonstrance, and wounds one of the number in the leg.
This was, in my opinion, a hasty and unauthorized act in the
use of a deadly weapon, not in defense of himself or family or
premises, but the offspring of a spirit of retaliation for what he erro-
neously supposed to have been done, and whose error could have
at once been corrected. If death had ensued, the circumstances
would not have excused the homicide, and as it was not fatal it
cannot be less than an assault.
Human life is too safely guarded by law to allow it to be put
in peril upon such provocation, and however much it may palliate
the defendant's impulse and the rash act in which it resulted, it
cannot, in my opinion, excuse his use of a deadly instrument in so
reckless a manner.
Per Curiam. Venire de novo.
252 Cases on Criminal Law.
SECTION III.
INFANCY.
(a) Responsibility of Infants.
Item. A girl of thirteen years of age was burnt because
while she was servant to a woman she killed her mistress : and it
was found to be so and adjudged treason. And it was said that
by the old law no one under age was hung, or suffered judgment
of life or limb. But Spigurnel found that an infant of ten years of
age killed his companion and concealed him ; and he caused him
to be hung, because by the concealment he showed that he knew
how to distinguish between evil and good. And so malice makes
up for age. Year Book, \ 2 Edward III., 626.
GODFREY V STATE.
Supreme Court of Alabama, 1858.
31 Alabama, 323.
Walker, J.^ The single point to be considered in this case,
is, whether the charge of the court below to the jury was correct.
An analysis of that charge shows that the jury were distinctly
instructed, that the defendant, being between seven and fourteen
years of age, was, prima facie, incapable of committing crime;
that to overturn the intendment in favor of his incapacity to com-
mit crime, the jury must be convinced from the evidence beyond
a reasonable doubt, after allowing due consideration to the fact that
the accused was a negro and a slave, that he knew fully the nature
of the act done, and its consequences ; and that he showed plainly
intelligent design and malice in the execution of the act. This
charge, after an anxious and careful examination of it, we can not
pronounce erroneous.
^ The opinion only is printed.
Cases on Criminal Law. 253
An infant, above seven, but under fourteen years of age, is
presumed not to have such knowledge and discretion, as would
make him accountable for a felony committed during that period.
But, if that presumption is met by evidence clearly proving the
existence of that knowledge and discretion deemed requisite to a
legal accountability, the reason for allowing an immunity from
punishment ceases, and, with it, the rule which grants such immu-
nity ceases. There are many cases where children between those
ages, being shown to have been cognizant of the criminal nature
of the act done, have been punished under the criminal law. A
girl, thirteen years of age, was executed for killing her mistress.
Two boys, one nine, and the other ten years of age, were con-
victed of murder, because one of them hid himself, and the other
hid the dead body ; thus manifesting, as was supposed, a con-
sciousness of guilt, and a discretion to discern between good and
evil. A boy of eight years of age, who had malice, revenge, and
cunning, was hanged for firing two barns. A boy ten years old,
who showed a mischievous discretion, was convicted of murdering
his bed-fellow. 4 Bla. Com. 23-24.
In the case of Rex v. Owen, 2 Car. & P., 236, it was referred
to the jury, to determine whether the act of a girl ten years old,
alleged to constitute a larceny, was known by her to be wrong
when it was done ; and, upon that question, she was acquitted.
It is said in Hale's Pleas of the Crown, page 22, that one between
the ages of seven and fourteen might be convicted of a capital
offense, "if it appeared by strong and pregnant evidence and cir-
cumstances that he was perfectly conscious of the nature and
malignity of the crime." In an American case the same principle
is thus stated : " If it shall appear by strong and irresistible evi-
dence that he had sufficient discernment to distinguish good from
evil, to comprehend the nature and consequences of his acts, he
may be convicted, and have judgment of death." State v, Aaron,
I Southard, N. J. R., 231. In that case, a negro boy, who was
a slave, of eleven years, was convicted of murder ; but a new trial
was granted on account of an erroneous ruling as to the compe-
tency of a witness, and it does not appear what farther was done
in the case.
In the case of the State v. Guild, 5 Halst. 163, a negro slave,
of less than twelve years, was convicted of murder ; and the report
254 Cases on Criminal Law.
of the case informs us, that the defendant was executed. In that
case, the court, dissenting from the cautious statement of the law
found in Hale's Pleas of the Crown, vol. i, p. 27, per-
mitted a conviction upon confessions. In this case, although a
confession was given in evidence, the facts proved estabhshed the
guilt of the accused so clearly, that it is fairly inferrible that no
importance was attached to it by the court or jury, and its effect
is not noticed in the charge. The question, whether a conviction
could be had upon confessions, does not arise, and we do not com-
mit ourselves to the doctrine of the decision last above cited upon
that point.
All the authorities concur in maintaining the correctness of
the propositions of law involved in the charge. Bishop on Crim-
inal Law, §§ 283, 284, 285 ; I Archbold's Crim. PL, 3, 4, and 5,
and notes ; i Russell on Crimes, 3, 4, and 5 ; Roscoe's Crim. Ev.,
942, 944 ; Wharton's Am. Crim. Law, 51; i Wheeler's Crim.
Cases, 231 to 234. Reason, humanity, and the law, alike required
that the court should, in its charge, throw around the jury every
guard and restriction necessary to prevent an improper conviction
in such a case. This has been carefully done by the court in this
case, and we are bound to pronounce a full approval of the charge.
The judgment of the city court is affirmed, and its sentence
must be executed.^
1 Accord: When the offense charged is a misdemeanor ; vagrancy, C. ex
rel, V. M'Keagy, i Ash. (Pa.) 248 (1828); battery, State v. Goin, 9 Humph.,
175 (1848); illegal sale of liquor, C. v. Mead, 92 Mass., 398 (1865). — Ed.
" No person shall in any case be convicted of any offense committed
before he was of the age of nine years ; nor, of any offense committed between
the years of nine and thirteen unless it shall appear by proof that he had
discretion to understand the nature and illegality of the act constituting the
offense."
Penal Code of Texas, Art. 34.
Section 283 of the Criminal Code of Illinois fixes the age at which
criminal responsibility attaches, at ten years.
Cases on Criminal Law. 255
INFANCY. {Continued.)
{b) Proof of Age.
STATE V. ARNOLD.
Supreme Court of North Carolina, 185 i.
13 Iredell, 184.
Appeal from the Superior Court of Law of Columbus County,
at the Fall Term, 185 1, his Honor Judge Battle, presiding.
This is an indictment for the murder of Simon Dyson. The
prisoner appeared at his trial, in October, 1850, to be a small boy,
but his age was not stated. Evidence was given on the part of the
State, that, within a week or two before the homicide, the prisoner
had several times expressed ill-will towards the deceased, and
threatened to kill him^.
The counsel for the prisoner alleged, that he was, apparently,
under the age of fourteen years, and, therefore, that it was incum-
bent on the State to prove, that he was over that age, or, if under
it, that he had such knowledge of right and wrong, as would ren-
der him responsible for the homicide, if he committed the act. The
court held the 07ius of proof to lie on the prisoner, as to his age.
The prisoner was convicted, and from the judgment on the convic-
tion, appealed to this court.
RuFFiN, C.J. Onthe last point the court is also of opinion, that
there was no error. The objection assumed as a fact, that the prisoner
appeared to be under fourteen years of age. As there was no proof
on the point, it could only be judged of by inspection, and, so far
as that goes, it must be taken to have been decided against the
prisoner, both by the court and the jury. As the subject of direct
proof, the onus was certainly on the prisoner, as the reputed age of
every one is peculiarly within his own knowledge, and also the per-
sons by whom it can be directly proved.
Per Curiam. There is no error in the judgment, and the cer-
tificate will issue accordingly.
^Only so much of this case as relates to proof of age is printed.
256 Cases on Criminal Law.
SECTION IV.
INSANITY.
(«) Test of Insanity.
Nota reader, every act which a man non compos doth, either
concerns his life, his lands, or his goods * * * as to his life,
the law of England is that he shall not lose his life for felony or
murder, because the punishment of a felon is so grievous. * * *
2. No felony or murder can be committed without a felonious
intent and purpose. * * * Also for the same reason, «« compos mentis
cannot commit petit treason, as if a woman non compos mentis, kills
her husband, as appears 12 H., 3. Forfeiture 33. But in some
cases non compos mentis may commit high treason, as if he kills, or
offers to kill the king, it is high treason, for the king est caput et
salus reipublicce, et a capitis bona valetudo transit in omnes ; and for
this reason their persons are so sacred, that none can offer them any
violence, but he is reus criminis laesae majestatis, et pereat unus ne
pereant omnes. And it must be known that there are four manners
oi non compos mentis ; i. Idiot or fool natural : 2. He who was of
good and sound memory, and by the visitation of God has lost it •.
3. Lunaticus, qui gaudet lucidis intervallis, and sometimes is of
good and sound memory, and sometimes non compos mentis :
4. By his own act, as a drunkard.
Beverley's Case, 1603, 4 Coke, p. 124.
M'NAGHTEN'S CASE.
House of Lords, 1843.
10 Clark and Finnelly, 200.
Daniel M'Naghten having been tried in the Central Criminal
Court for the murder of Edward Drummond, the jury returned a
verdict "not guilty" on the ground of insanity.
This verdict and the question of the nature and extent of the
unsoundness of mind which would excuse the commission of a
Cases on Criminal Law. 257
felony of this sort, having been made the subject of debate in the
House of Lords, it was determined to take the opinion of thejudges
on the law governing such cases. Accordingly, on the 26th of May
all the judges attended their lordships, but no questions were then
put.
On the 19th of June thejudges again attended the House ot
Lords, when (no argument having been had) the following ques-
tions of law were propounded to them:^
Lord Chief Justice Tindall. The first question proposed
by your lordships is this: "What is the law respecting alleged
crimes committed by persons afflicted with insane delusion in respect
of one or more particular subjects or persons ; as, for instance,
where at the time of the commission of the alleged crime the
accused knew he was acting contrary to law, but did the act com-
plained of with a view, under the influence of insane delusion, of
redressing or revenging some supposed grievance or injury, or of
producing some supposed public benefit ?"
In answer to which question, assuming that your lordships'
inquiries are confined to those persons who labor under such par-
tial delusions only, and are not in other respects insane, we are of
opinion that, notwithstanding the party accused did the act com-
plained of with a view, under the influence of insane delusion, of
redressing or revenging some supposed grievance or injury, or of
producing some public benefit, he is nevertheless punishable accord-
ing to the nature of the crime committed, if he knew at the time of
committing such crime that he was acting contrary to law ; by
which expression we understand your lordships to mean the law of
the land.
Your lordships are pleased to inquire of us secondly, " What
are the proper questions to be submitted to the jury, where a per-
son alleged to be afflicted with insane delusion respecting one or
more particular subjects or persons, is charged with the commission
of a crime (murder, for example), and insanity is set up as a
defence ?" And, thirdly, " In what terms ought the question to be
left to the jury as to the prisoner's state of mind at the time when '
the act was committed ? " And as these two questions appear to
us to be more conveniently answered together, we have to submit
"^The questions appear in the opinion.
258 Cases on Criminal Law.
our opinion to be, that the jurors ought to be told in all cases that
every man is to be presumed to be sane, and to possess a sufficient
degree of reason to be responsible for his crimes until the con-
trary be proved to their satisfaction ; and that to establish a defence
on the ground of insanity, it must be clearly proved that, at the time
of the committing of the act, the party accused was laboring under
such a defect of reason, from disease of the mind, as not to know the
nature and quality of the act he was doing; or, if he did know'it,
that he did not know he was doing what was wrong. The mode of
putting the latter part of the question to the jury on these occasions
has generally been, whether the accused at the time of doing the act
knew the difference between right and wrong : which mode, though
rarely, if ever, leading to any mistake with the jury, is not, as we
conceive, so accurate when put generally and in the abstract, as
when put with reference to the party's knowledge of right and
wrong in respect to the very act with which he is charged. If the
question were to be put as to the knowledge of the accused solely
and exclusively with reference to the law of the land, it might tend
to confound the jury, by inducing them to believe that an actual
knowledge of the law of the land was essential in order to lead to
a conviction ; whereas the law is administered upon the principle
that every one must be taken conclusively to know it, without proof
that he does know it. If the accused was conscious that the act
was one which he ought not to do, and if that act was at the same
time contrary to the law of the land, he is punishable ; and the
usual course, therefore, has been to leave the question to the jury,
whether the party accused had a sufficient degree of reason to know
that he was doing an act that was wrong ; and this course we think
is correct, accompanied with such observations and explanations as
the circumstances of each particular case may require.
The fourth question which your lordships have proposed to us
is this : " If a person, under an insane delusion as to existing
facts, commits an offence in consequence thereof, is he thereby
excused?" To which question the answer must, of course, depend
on the nature of the delusion ; but, making the same assumption
as we did before, namely, that he labors under such partial delu-
sion only, and is not in other respects insane, we think he must be
considered in the same situation as to responsibility as if the facts
with respect to which the delusion exists were real. For example,
Cases on Criminal Law. 259
if, under the influence of his delusion, he supposes another man to
be in the act of attempting to take away his life, and he kills that
man, as he supposes, in self defence, he would be exempt from pun-
ishment. If his delusion was that the deceased had inflicted a
serious injury to his character and fortune, and he killed him in
revenge for such supposed injury, he would be liable to punishment.
The question lastly proposed by your lordships is : " Can a
medical man conversant with the disease of insanity, who never saw
the prisoner previously to the trial, but who was present during the
whole trial and the examination of all the witnesses, be asked his
opinion as to the state of the prisoner's mind at the time of the com-
mission of the alleged crime ? or his opinion whether the prisoner
was conscious at the time of doing the act that he was acting con-
trary to law, or whether he was laboring under any and what
delusion at the time?" In answer thereto, we state to your lord-
ships, that we think the medical man, under the circumstances sup-
posed, cannot in strictness be asked his opinion in the terms above
stated, because each of those questions involves the determination
of the truth of the facts deposed to, which it is for the jury to decide,
and the questions are not mere questions upon a matter of science,
in which case such evidence is admissible. But where the facts are
admitted or not disputed, and the question becomes substantially
one of science only, it may be convenient to allow the question to
be put in that general form, though the same cannot be insisted on
as a matter of right. ^
Cox, J., in Guiteau's Case, 10 Fed., 161 (1882). "An insane
delusion is never the result of reasoning and reflection. It is not
generated by them and it cannot be dispelled by them. A man may
reason himself, and be reasoned by others, into absurd opinions,
and may be persuaded into impracticable schemes and vicious
resolutions, but he cannot be reasoned or persuaded into insanity
or insane delusions. Whenever convictions are founded on evi-
dence, or comparisons of facts and opinions and arguments, they
are not insane delusions."
Henderson, J., in Merritt v. St., 39 Tex. Cr. R., 78, (1898).
' ' We gather from the authorities that a delusion need not be con-
1 The proceedings of the Trial Court, and the opinion of Maule, J., are
omitted.
26o Cases on Criminal Law.
fined, as was formerly held, to the delusive belief of a fact which, if
true, would afford a justification. But if the delusion was of such
a character as to impair the mind of the person possessed thereof, to
such an extent that the person was not able to discern the right or
wrong of the particular act he was doing, and was induced to com-
mit the particular act by the delusion, he would not be a criminal.
Mr. Bishop, after stating the rule about as Mr. Wharton does, supra
uses this language: ' This branch of the doctrine should be
cautiously received, for delusion of any kind is strongly indicative
of a generally diseased mind, and doubtless sometimes, if not
always, does in fact extend beyond the precise point we have sup-
posed, whether perceptible to the casual eye or not.' "
COMMONWEALTH v. MOSLER.
Oyer and Terminer of Philadelphia, 1846.
4 Pennsylvania, 264.
The prisoner was indicted for the murder of Eve Mosler, his
wife. The evidence being closed, after argument by Stokes, and
Read, Attorney General, for the Commonwealth, and Barnes and
Barton for the defence, the jury was charged as follows : ^
Gibson, C. J. The fact of the killing is not denied. Two
points of defence have been set up ; the first, that of insanity,
implying an entire deprivation on the part of the prisoner, of the
power of self-control, and constituting a complete defence to the
charge ; the second, that of temporary fury induced by adequate
provocation, reducing the offence to manslaughter. The first, if
sustained, will acquit him altogether ; the second, while acquitting
him of murder, will leave him guilty of manslaughter.
Insanity is mental or moral ; the latter being sometimes called
homicidal mania, and properly so. It is my purpose to deliver to
you the law on this ground of defence, and not to press upon your
consideration, at least to an unusual degree, the circumstances of
the present case on which the law acts.
A man may be mad on all subjects ; and, then, though he may
' Part of this case is omitted.
Cases on Criminal Law. 261
have glimmerings of reason, he is not a responsible agent. This is
general insanity ; but if it be not so great in its extent or degree as
to blind him to the nature and consequences of his moral duty, it is
no defence to an accusation of crime. It must be so great as
entirely to destroy his perception of right and wrong ; and it is not
until that perception is thus destroyed, that he ceases to be responsi-
ble. It must amount to delusion or hallucination, controlling his
will, and making the commission of the act, in his apprehension, a
duty of overruling necessity. The most apt illustration of the
latter is the perverted sense of religious obligation which has caused
men sometimes to sacrifice their wives and children.
Partial insanity is confined to a particular subject, the man
being sane on every other. In that species of madness, it is plain
that he is a responsible agent, if he were not instigated by his mad-
ness to perpetrate the act. He continues to be a legitimate subject
of punishment, although he may have been laboring under a moral
obliquity of perception, as much so as if he were merely laboring
under an obliquity of vision. A man whose mind squints, unless
impelled to crime by this very mental obliquity, is as much amen-
able to punishment as one whose eye squints. On this point there
has been a mistake as melancholy as it is popular. It has been
announced by learned doctors that if a man has the least taint of
insanity entering into his mental structure, it discharges him of all
responsibility to the laws. To this monstrous error may be traced
both the fecundity in homicides, which has dishonored this country,
and the immunity that has attended them. The law is, that
whether the insanity be general or partial, the degree of it must be
so great as to have controlled the will of its subject, and to have
taken from him the freedom of moral action.
But there is amoral or homicidal insanity, consisting of an
irresistible inclination to kill, or to commit some other particular
offence. There may be an unseen ligament pressing on the mind,
drawing it to consequences which it sees, but cannot avoid, and
placing it under a coercion which, while its results are clearly per-
ceived, is incapable of resistance. The doctrine which acknowledges
this mania is dangerous in its relations, and can be recognized
only in the clearest cases. It ought to be shown to have been
habitual, or at least to have evinced itself in more than a single
instance. It is seldom directed against a particular individual ; but
262 Cases on Criminal Law.
that it may be so, is proved by the case of the young woman who
was deluded by an irresistible impulse to destroy her child, though
aware of the heinous nature of the act. The frequency of this con-
stitutional malady is fortunately small, and it is better to confine it
within the strictest limits. If juries were to allow it as a general
motive operating in cases of this character, its recognition would
destroy social order as well as personal safety. To establish it as
a justification in any particular case, it is necessary either to show,
by clear proofs, its contemporaneous existence evinced by present
circumstances, or the existence of an habitual tendency developed
in previous cases, becoming in itself a second nature. Now, what
is the evidence of mental insanity in this particular case ?
1. The prisoner's counsel rely on his behavior, appearance
and exclamations at the time of the act, or immediately after it.
According to one witness, his conduct was that of reckless deter-
mination, evincing an unsound mind. " I did it," he repeated three
times, it is said, like a raving maniac. But you must recollect that
to commit murder, a man must be wound up to a high pitch of
excitement. None but a butcher by trade could go about it with
circumspection and coolness. The emotion shown by the prisoner
was not extraordinary. He seemed to know the consequences
of his act — was under no delusion — and was self possessed enough
to find a reason for the act, that reason being her alleged
ill treatment.
2. It is urged that the want of motive is evidence of insanity.
If a motive were to be necessarily proved by the Commonwealth,
it is shown in this case by the prisoner's own declaration; but a
motive need not always be shown — it may be secret; and to hold
every one mad whose acts cannot be accounted for on the ordinary
principles of cause and effect, would give a general license. The
law itself implies malice, where the homicide is accompanied with
such circumstances as are the ordinary symptoms of a wicked,
depraved and malignant spirit — a heart regardless of social duty,
and deliberately bent upon mischief.
3. But it is said that there is intrinsic evidence of insanity from
the nature of the act. To the eye of reason every murderer may
seem a madman ; but in the eye of the law he is still responsible.
4. His trip to Pittsburgh and voyage to Germany, it is con-
tended, have not been accounted for, except that he expected to
Cases on Criminal Law. 263,
get property in the latter, but did not ; and there is an equal
obscurity about the motives of his setting fire to his wife's property —
her barn, I think it was ; but these things do not show any insanity
connected with his crime.
The only circumstance which seems to point to a foregone
conclusion, is the repeated visions he had after he started for Pitts-
burgh, of his wife and her grand-daughter, whose throat he also
attempted to cut, standing at the foot of his bed. This foreboding
may tend to show a morbidness of mind in reference to this particu-
lar subject ; but it is for you to say — keeping in mind the fact that
to constitute a sufficient defence on this ground, there must be an
entire destruction of freedom of the will, blinding the prisoner to
the nature and consequence of his moral duty — whether these
circumstances raise a reasonable doubt of the- prisoner's responsi-
bility.
After an absence of two hours, the jury returned to their box
with a verdict of guilty of murder in the first degree.^
STATE V. HARRISON.
Supreme Court of Appeals of West Virginia, 1892.
36 West Virginia, 729.
Brannon, Judge.^ On the 14th day of April, 1892, Allen
Harrison was sentenced to death by the Circuit Court of Cabell
county for the murder of Bettie Adams, and he comes to this
Court for relief from that sentence.
Is there error in refusing instruction twenty-one ? That in-
struction is in the following words: "The court instructs the
jury that a man may have reason and intelligence sufficient to
enable him to distinguish and know the difference between right
1 Accord : Holding "irresistible impulse" excuses, Green v. St., 64 Ark.,
523 (1898); St. V. Johnson, 40 Conn., 136(1873); St.' w. Cole, 2 Pennewill,
(Del.), 344 (1899) ; Flanagan v. St., 103 Ga., 619 (1898); Plake v. St., 121
Ind., 433 (1889); [Semble Fouts v. St., 4 G. Greene (Iowa), 500 (1854] ;
Smith V. C, I Duv. (Ky.), 224 (1864); Blackburn v. St., 23 Ohio St., 146
(1872); Dejarnette v.C, 75 Va., 867 (1881); Butler w. St., 102 Wis., 364
(1899)— Ed.
^ Only so much of the opinion as relates to the test of insanity is printed.
264 Cases on Criminal Law.
and wrong. He may know that the act he is about to commit is
wrong ; and yet, if from defect, weakness, or disease of the mind,
he is incapable of controlling his acts, and of resisting the impulse
to commit the act, then the act, however great a crime it may be,
is not a wilful act, and therefore not criminal. Therefore, if the
jury believe that, although the prisoner^ Allen Harrison, at the
time of the commission of the alleged crime, knew it was wrong,
yet if the jury believe and are satisfied from the evidence in this
case, that his will power was so impaired by disease or otherwise
as to render him incapable of controlling his acts or resisting the
impulse so to do, then the killing of Bettie Adams under such cir-
cumstances was not the wilful act of the prisoner, and he should
not be held criminally responsible therefor."
This instruction requires us to say whether it proposes a
proper legal test of criminal responsibility. It is based upon the
theory above mentioned, that, though a person have capacity to
know right from wrong, and to know that the particular act is
wrong, yet if he has not will power to avoid the act, if he is insti-
gated to it by uncontrollable impulse, he is not criminally liable ;
and that the " right and wrong " test is not the proper test, as it
excludes the effect of uncontrollable impulse. It is conceded that
this instruction is not good under the criminal law as stated in the'
earlier text-books and decisions, but it is claimed that it is sustained
by the later and better decisions and text writers.
Lords Coke and Hale wrote that to exonerate from crime on
account of insanity a man must be totally deprived of memory
and understanding ; and Justice Tracy, on Arnold's trial in 1724,
16 St. Trials, 695, said he must be one totally deprived of memory
and understanding, and doth not know what he is doing, no more
than an infant, a brute, or wild beast.
These statements are not recognized in their fullness in later
years, yet in modern cases the courts have generally stated the
question of responsibility to be whether, at the time the prisoner
committed the act, he had mental capacity to know right from
wrong, and comprehend his relations to others, and to understand
the nature and consequence of the particular act, and that the act
was morally wrong, or, what is the same, whether he was conscious
of doing wrong. i Bish. Crim. Law, § 475.
This is the " right and wrong " test, as commonly called. It
Cases on Criminal Law. 265
has had for a long time, and has to-day, the sanction of the most
eminent legal authority, those best acquainted with the real and
practical demands of the daily administration of justice, as best
suited to it, all things considered, and as at once the safest rule for
the protection of human life and the preservation of those charged
with crime. In 1843, i^ answer to questions propounded by the
House of Lords as to crimes committed by persons afflicted with
insane delusions in respect to one or more particular persons or
subjects, and what were proper questions to be submitted to a jury
in such case, and in what terms the question should be left to the
jury as to the prisoner's state of mind at the time of the act, the
judges of England laid down these principles :
" A person laboring under partial delusion only is nevertheless
punishable if he knew at the time of committing such crime he was
acting contrary to law ; " and " that the jury ought to be told in
all cases that every man is presumed to be sane, and to possess
sufficient reason to be responsible for his crimes, until the contrary
be proved to their satisfaction ; that to establish the defense of
insanity it must be clearly proved that at the time of committing
the act the party accused was laboring under such a defect of
reason, from disease of the mind, as not to know the nature and
quality of the act he was doing ; or, if he did know it, that he did
not know he was doing what was wrong. The mode of putting
the latter part of the question to the jury on these occasions has
generally been whether the accused, at the time of doing the act,
knew the difference between right and wrong, which mode, though
rarely, if ever, leading to any mistake with the jury, is not, as we
conceive, so accurate, when put generally and in the abstract, as
when put with reference to the party's knowledge of right and
wrong in respect to the very act with which he is charged." i
Russ. Crimes, 19; 2 Greenl. Ev., § 373, and note.
These answers of the judges are based on the " right and
wrong " test, and, though sometimes criticised, they have prevailed
in England since 1843. They do not recognize the doctrine of
irresistible impulse as an independent element of test. In New
York, in 1847, in Freeman v. People, 4 Denio, 9, these answers
of the English judges were recited as the law as it should be given
to the jury, and it was said that in murder trials, where insanity is
the defense, " the inquiry is always to be brought down to the
266 Cases on Criminal Law.
single question of a capacity to discriminate between right ancF
wrong at the time when the act was committed."
In Flanagan v. People, 52 N. Y., 467, the law was again
affirmed as set forth by the English judges, and the doctrine of
uncontrollable impulse, as co-existent with a perception of the moral
quality of the acts done, was rejected as a " new element " ; the
court saying : " We are asked to introduce a new element into-
the rule of criminal responsibihty in cases of alleged insanity, and
to hold that the power of choosing right from wrong is as essential
to legal responsibility as the capacity of distinguishing it, and that
the absence of the former is consistent with the presence of the
latter. The argument is on the theory that there is a form of in-
sanity in which the faculties are so disordered and deranged that a
man, though he perceives the moral quality of his acts, is unable
to control them, and is urged by some mysterious pressure to the
commission of the act, the consequences of which he anticipates
but cannot avoid. Whatever medical or scientific authority there
may be for this view, it has not been accepted by courts of law.
The vagueness and uncertainty of the inquiry which would be
opened, and the manifest danger of introducing the limitation
claimed into the rule of responsibility, in cases of crime, may well
cause courts to pause before assenting to it. Indulgence in evii
passions weakens the restraining power of the will and conscience,
and the rule suggested would be the cover for the commission of
crime and its justification. The doctrine that a criminal act may
be excused upon the notion of an irresistible impulse to commit it,
where the offender has the abiHty to discover his legal and moral,
duty in respect to it, has no place in the law. Rolfe, B., in
Rogers v. Allunt, where, on a trial for poisoning, the defendant
was alleged to have acted under some moral influence which he
could not resist, said : " Every crime was committed under an-
influence of such a description ; and the object of the law was to
compel people to control this influence.''
The New York Court laid down the law to be that " the test
of responsibility is the capacity of defendant to distinguish between
right and wrong at the time of and in respect to the act complained^
of," and that " the law does not recognize a form of insanity in
which the capacity of distinguishing right from wrong exists without,
the power of choosing between them."
Cases on Criminal Law. 267
Later, in People v. Carpenter, 102 N. Y., 238 (6 N. E. Rep.,
584), this doctrine is again held. In 1889 the South Carolina
Supreme Court held that " mere irresistible impulse to commit
murder by reason of mental derangement at the time of the act
is not a defense, as long as the accused knew that the act he was
committing was a crime morally, and punishable by law." State v.
Alexander, 30 S. C, 74 (8 S. E. Rep., 440).
In the debate of the House of Lords upon the answer of the
fourteen judges of England to the questions propounded by the
House of Lords, Lord Brougham said that if the perpetrator knew
what he was doing ; if he had taken the precaution to accomplish
his purpose ; if he knew at the time of doing the desperate act,
that it was forbidden by law — that was his test of sanity, and he
cared not what judge had given another test, he should go to his
grave believing it was the real, sound and consistent test. I fully
concur with Lord Brougham.
In Reg. V. Barton, 3 Cox Crim. Cas., 278, that great jurist
Baron Parke said the single question was whether, at the time of
the act, the prisoner knew the nature and character of the deed, and,
if so, whether he knew he was doing wrong ; and further said that
he concurred with the view previously taken by Baron Rolfe that
the excuse of an irresistible impulse co-existing with the full pos-
session of the reasoning powers, if allowed as a defense, might be
urged in justification of every crime ; for every man might be said
not to commit crime except under the influence of some irresistible
impulse ; that something more than this was necessary to justify
acquittal on the ground of insanity ; and it would be for the jury-
to say whether the impulse under which the prisoner had committed
the deed, was one which altogether deprived him of knowledge
that he was doing wrong.
In U. S. V. Holmes, i Clifif., 98, Mr. Justice Clifford point-
edly rejected the "irresistible impulse " test, after a review of the
cases. He said that it had been suggested that the rule in the
State courts was different from the English rule, but that his exam-
ination had led him to the conclusion that the great majority of the
well-considered cases followed the English judges ; and on another
page he says all the well-considered cases in both countries since
1843 followed their answers. He said that, in case of partial in-
sanity, it is a question for the jury to determine, under all the
268 Cases on Criminal Law.
evidence, whether the degree of insanity is sufficient to constitute
a valid defense ; " and if it appears that the mind of the accused is
merely clouded and weakened, but is not incapable of reasoning
and judging between right and wrong in respect to his own particu-
lar act, that he still understands the nature and character of the act
and its consequences, and has a knowledge that it is wrong and
criminal, and mental power sufficient to apply that knowledge to
his own case, and to know that if he does the act he will do wrong
and deserve punishment, then the law on that state of facts properly
regards the accused as a moral agent, responsible for his criminal
acts, and punishable for the crime ; and to admit, in such a case,
that the defense may be set up successfully that he was impelled
to the commission of the act by any uncontrollable or irresistible
impulse, would be to overlook and disregard the test or criterion
of responsibility for criminal acts which the law itself establishes
in such a case, and to allow that defense in justification of every
crime known to the law."
Courts have to ask themselves what is meant by that insanity
which excuses from crime because of incapacity to entertain
criminal intent. The infinite and intricate phases of disorders of
the mind are interesting, and their study necessary in that noble
science which gives relief in the most distressing and saddest of
human ailments, and which in our days, unlike the days of Shake-
speare, " can minister to a mind diseased, pluck from the memory
a rooted sorrow, raze out the written troubles of the brain." But
the law is not a metaphysical or theoretical science ; it must follow
principles suitable to the practical wants of men in organized society
by protecting it against heinous crime.
Mr. Justice Curtis, in U. S. v. McGlue, i Curt., 9, adopted
the " right and wrong " test as the test which the law applied, and
said these were the questions for the jury : " Did the prisoner
understand the nature of the act when he stabbed Mr. Johnson ?
Did he know he was doing wrong, and would deserve punishment?
Or, to apply them more nearly to this case, did the prisoner know
that he was killing Mr. Johnson ; that to do so was criminal and
deserving punishment ? If so, he had the criminal intent neces-
sary to convict him of murder, and cannot be acquitted on the
ground of insanity."
The " irresistible impulse" test has been pointedly rejected
Cases on Criminal Law. 269
also in Missouri in State v. Pagels, 92 Mo., 300 (4 S. W. Rep.,
931), the Court saying ; " It will be a bad day for this State when
uncontrollable impulse shall dictate a rule of action to our Courts."
It has been specifically rejected twice in Kansas. State v. Nixon,
32 Kan., 205 (4 Pac. Rep., 159); State v. Mowry, 37 Kan., 369
(15 Pac. Rep., 282), and in North Carolina in State v. Brandon, 8
Jones (N. C), 463. See 4 Amer. & Eng. Enc. Law, 718.
Mr. Bishop does not regard this test as adopted, for in i
Crim. Law, § 475, he says the " right and wrong " test is the one
generally applied by the courts ; and in section 478 he says that
it is understood in science, and sometimes recognized in courts,
though judges are slow to yield on the point, that the mental and
physical machine may slip the control of the owner, and so a man
may be conscious of what he is doing, and its criminal character
and consequences, while yet he is impelled onward by a power
irresistible. But he says this is not the rule of the courts.
In Illinois, in two cases, it is held as to the defense of irresisti-
ble impulse, that it must proceed from an unsound mind affected
with insanity " to such a degree as to create an uncontrollable im-
pulse to do the act by overriding his reason and judgment."
Hopps V. People, 31 111., 391 ; Dacey v. People, 116 111., 555 (6
N. E. Rep., 165). In other words, the party, because of insanity,
knew not the wrong of the act.
The California Supreme Court, in People v. Hoin, 62 Cal.,
120, held that an irresistible impulse to commit a criminal act
" does not absolve the actor, if at the time and in respect to the
act he had the power to distinguish between right and wrong."
In Maine, an instruction based substantially upon it was held
to have been properly rejected. State v. Lawrence, 57 Me., 577,
S8i.
The cases are almost without number which, while not pass
ing on the " irresistible impulse " test expressly, yet logically
exclude it, because they lay down the "right and wrong" test
above stated. See note to .State v. Marler, 36 Amer. Dec, 407 ;
note to Guiteau's Case, 10 Fed. Rep., 195. The "right and
wrong " test was approved in the Guiteau Case. In a few States
the " irresistible impulse" test is upheld. See notes just cited.
The case of Parsons v. State, 81 Ala., 577 (2 South Rep.,
854), is cited to us as one of the best considered cases support
27° Cases on Criminal Law.
this rule, holding that, though there be a capacity to distinguish
between right and wrong, as applied to the particular act, still the
party is not responsible if by reason of duress of mental disease he
has so far lost the power to choose between right and wrong as not
to avoid doing the act, so that his free agency was at the time de-
stroyed, and at the same time the crime was so connected with such
mental disease, in relation of cause and effect, as to have been the pro-
duct or offspring of it solely. A dissenting opinion of great ability
was filed to that decision, and it overruled a decision to the reverse
in Alabama in Boswell's Case, 63 Ala., 307. So also, Smith v. Com.,
I Duv., 224. So also, held the Indiana Court in Stevens v. State,
31 Ind., 485. The opinion in the last case plants this decision on
the opinion of Chief Justice Shaw in Com. v. Rogers, 7 Mete.
(Mass.), 500.
It struck me that the opinion of Chief Justice Shaw not only
did not support this view, but supported the " right and wrong"
test ; and I find that Mr. Justice Clifford concurs in this view by
citing Chief Justice Shaw's opinion in support of the "right and
wrong" test in U. S. v. Holmes, supra.
Chief Justice Shaw said, as to the cases of partial insanity,
the rule of law is this : "A man is not to be excused from responsi-
bility if he has capacity and reason sufficient to enable him to dis-
tinguish between right and wrong as to the particular act he is
then doing ; a knowledge and consciousness that the act is wrong
and criminal, and will subject him to punishment. In order to be
responsible, he must have sufficient power of memory to recollect
the relation in which he stands to others, and in which others
stand to him, and that the act he is doing is contrary to the plain
dictates of justice and right, injurious to others, and a violation of
the dictates of duty. On the contrary, although he may be labor-
ing under partial insanity, if he still understands the nature and
character of his act and its consequences, if he has a knowledge
that it is wrong and criminal, and a mental power sufficient to
.apply that knowledge to his own case, and to know that if he does
the act he will do wrong, and receive punishment — such partial
insanity is not sufficient to exempt him from responsibility for
criminal acts."
The words, " mental power sufficient to apply that knowledge
t.0 his own case," mean only capacity to apply his knowledge of
Cases on Criminal Law. 271
right and wrong to the particular act so as to know whether it is
wrong. The judge did not mention will power. I cannot see how
the eminent Chief Justice Shaw can be quoted on this statement
■of the rule, as favoring the " irresistible impulse " test.
The eminent Chief Justice Dillon is quoted as approving
this test in State v. Felter, 25 Iowa, 67 ; whereas his opinion can-
not be so regarded. He did say the "right and wrong " test
should not be applied too strictly in all cases. He admitted that
the cases of authority recognized that a party was responsible if
he knew the act was wrong, but said that if it should, by the ob-
. servation and concurrent testimony of medical men, come to be
• definitely established as true that there is a diseased condition of
mind, in which, though the person knows abstractly that his act is
wrong, yet from insane impulse, proceeding from an insane mind,
,he is driven to the act irresistibly, then the law must be modified.
This is purely hypothetical or conditional ;. an admission that such
then was not the law. And in the actual decision he held as
proper, and not erroneous, an instruction based on the " right and
-wrong " test, and said :
"With reference to the ' right and wrong ' test referred to
rin the instructions, it will be seen that the court does not adopt
this criterion as a general one ; that is, it does not say that, if the
defendant has capacity to distinguish between right and wrong
generally, he is criminally responsible. But it held that if at the
time and with respect to the act about to be committed the defend-
.ant had not reason enough to discriminate between right and wrong
with reference to that act, and had not reason enough to know the
nature of the crime, and did not know that he was doing wrong in
committing it, he is not criminally punishable. The court, in sub-
stance, held that if the defendant's reason was so far gone or over-
whelmed that his perception of right or wrong with respect to the
contemplated act was destroyed ; if he did not rationally compre-
.hend the character of the act he was about to commit — he should
be acquitted. The instruction as given finds full support in the
judgments of courts the most respectable. Freeman v. People, 4
Denio, 27, approved in WiUis v. People, 32 N. Y., 715 ; State v.
Brandon, 8 Jones (N, C ), 463 ; Com. v. Mosler, 4 Pa. St., 264 ;
McNaghten's Case, 10 Clark & F., 210; Oxford's Case, 9 Car. &
P. 525-"
272 Cases on Criminal Law.
He thus quotes the very cases holding the " right and wrong "
test. How this case of State v. Felter can be cited to sustain the
"irresistible impulse" test, I am unable to see. And in the later
case of State v. Mewherter, 46 Iowa, 88, the court held that to
justify acquittal for uncontrollable propensity the insanity " must
be such as to destroy the power to comprehend rationally the nature
and consequences of his act, and overpower his will."
Several cases cited in note in 36 Amer. Dec, 407, as on the side
of the "irresistible impulse" test are not on its side, but against
it, some of them. Ortwein v. Com., '/6 Pa. St., 414; Com. v.
Mosler, 4 Pa. St., 264; Brown v. Com., 78 Pa. St., 122 ; Sayres
V. Com., 88 Pa. St., 291 ; State v. Gut, 13 Minn., 358 (Gil. 315);
State V. Shippy, 10 Minn., 229 (Gil. 178); Blackburn v. State, 23
Ohio, 146, and others. The " irresistible impulse " test seems to
meet the approval 'of the distinguished law-writer, Mr. Wharton.
Whart. Horn. § 574; i Whart. Crim. Law, § 44 ; I Whart. & S.
Med. Jur. § 147.
This " irresistible impulse " test has been only recently pre-
sented, and, while it is supported by plausible arguments, yet it is
rather refined and introduces what seems to me a useless element
of distinction for a test, and is misleading to juries and fraught with
great danger to human life, so much so that even its advocates
have warningly said it should be very cautiously applied, and only
in the clearest cases. What is this " irresistible impulse ? " How
shall we of the courts and juries know it ? Does it exist when mani-
fested in one single instance, as in the present case, or must it be
shown to have been habitual, or, at least, to have evinced itself in
more than a single instance, as Chief Justice Gibson said must be
the case? We have kleptomania and pyromania, which better
works on medical jurisprudence tell us cannot excuse crime where
there is capacity to know the character of the act. Whart. & St
Med. Jur. §§ 592, 602, 616. Shall we introduce homicidal mania
and allow him of the manslaying propensity to walk innocent
through the land while yet not insane, but capable of knowing the
nature and wrong of his murderous act?
For myself I cannot see how a person who rationally compre-
hends the nature and quality of an act, and knows that it is wrong
and criminal, can act through irresistible innocent impulse. Knowing
the nature of the act well enough to make him otherwise liable for
Cases on Criminal Law. 27 j
it under the law, can we say that he acts from irresistible impulse,
and not criminal design and guilt ? And if we are sure he was
seized and possessed and driven forward to the act wholly and abso*
lutely by irresistible impulse, his mind being diseased, how can we
say he rationally realized the nature of the act — realized it to an
extent to enable us to hold him criminal in the act ? How can the
knowledge of the nature and wrongfulness of the act exist along
with such impulse as shall exonerate him ? Can the two co-exist ?
The one existing, does not the other non-exist ?
Can we certainly say that a person who is really driven to an
act by such an impulse is capable, at the instant of the act, of know-
ing its true nature ? The mother who threw her child overboard
into the billows of the deep was held innocent because she was pos-
sessed and impelled by the uncontrollable impulse to do so, while
yet she was conscious of the heinousness of the act. Can we
be sure she knew the character of the act ? If in fact she did, can
we safely say she was driven on by the mysterious spirit of irresisti-
ble impulse? So it appeared to the Kansas court in State v.
Nixon, 32 Kan., 205 (4 Pac. Rep., 159), where the court says :
"It is possible that an insane impulse is sometimes sufficient
to destroy criminal responsibility, but this is probably so only when
it destroys the power of the accused to comprehend rationally the
nature, character and consequences of the particular acts, and not
where he still has the power of knowing the character of the acts,
and that they are wrong. * * * T\\^ law will hardly recog-
nize the theory that an uncontrollable impulse may so take posses-
sion of a man's faculties and powers as to compel him to do what
he knows to be wrong and a crime, and thereby remove him from
all criminal responsibility. Whenever a man understands the
nature and character of an act, and knows that it is wrong, it would
seem that he ought to be held legally responsible for the commis-
sion of it."
After preparing this opinion, I met with Mr. Stephens's His-
tory of the Criminal Law of England. Mr. Stephens is quoted as
favoring the " irresistible impulse " theory, and in volume 2, pp.
1 70, 171, brings himself to the admission that one who is the subject
of such an impulse does not know that his act is wrong ; that one
who does know the right, and has power to choose the right over
the wrong, this very knowledge involving and including power of
274 Cases on Criminal Law.
self-control ; that so the rules laid down by the law ought to be
construed ; that the test of " knowledge that an act is wrong " is
the best and most proper test of accountability, and that such is the
test by the law of the land. He says : " Knowledge and power are
the constituent elements of all voluntary action, and if either is.
seriously impaired the other is disabled. It is as true that a man who
cannot control himself does not know the nature of his acts as that
a man who does not know the nature of his acts is incapable of
self-control."
I admit the existence of "irresistible impulse" and its efficacy
to exonerate from- responsibility, but not as consistent with an
adequate realization of the wrong of the act. It is that uncontrol-
able impulse produced by the disease of the mind, when that disease'
is s'ufficient to override the reason and judgment, and obliterate the
sense of right as to the act done, and deprive the accused of
power to choose between them. This impulse is born of the disease,
and when it exists, capacity to know the true nature of the act is
gone. This is the sense in which "irresistible impulse" was de-
fined in Hopps V. People, 31 111., 385, and Dacy v. People, 116
111., 556(6 N. E. Rep., 165).
It seems to me to be very dangerous to life to tell juries that
a party may know the nature of his murderous act, and know and
be conscious that it is wrong and criminal, and yet be excusable if
he did the act at the command of irresistible impulse ; thus eliminat-
ing the knowledge of the wrong of the act as an unessential, unim-
portant element in the test. I do not regard it as essential to the
safety of the parties accused.
The operations of the human mind are wonderful, mysterious
and occult. Insanity is one of its melancholy and impenetrable
conditions. Its types and phases are infinite and dark. Volumes
upon volumes have been compiled by writers upon medical juris-
prudence, mental philosophy and law to pierce its depths and find
the general rules which shall tell criminal courts what degree and
character of insanity shall avail to excuse crime ; but no general
rule universally applicable has been or can be found, because, as
Mr. Bishop says, it is not in the nature of the subject to extract
such a rule from it, I know of no better rule than the " right and
wrong " test, as above stated. Hence I do not think instruction
twenty-one is good in law.
Cases on Criminal Law. 275
The theory of irresistible impulse was so little borne out by the
evidence that it may be questioned whether the instruction based on
it, even if correct in law, was relevant to the case. He deliberately
and secretly prepared the pistol hours before the bloody and cruel
deed. He knew that the girl did not love him, and that marriage
with her was out of the question. It is simply another instance of
the many in the annals of criminal law where a man murders a
woman because she will not reciprocate his love, and because of
intense jealousy, perhaps mingled in this case with malice, because
he had been bidden to leave the house on her account. Solemn as
is the judgment, we are compelled to affirm it.
As the day fixed for the execution of the sentence has passed,
the case is remanded to the Circuit Court with direction to cause
the defendant to be brought before it and to fix another day for the
execution of the judgment. Affirmed}
STATE V. JONES.
Supreme Judicial Court of New Hampshire, 1871.
50 New Hampshire, 369.
Indictment against Hiram Jones for the murder of his wife.
The defendant was found guilty of murder in the first degree.
The defendant excepted to the following instructions given to
the jury :
If the defendant killed his wife in a manner that would be
criminal and unlawful if the defendant were sane, the verdict should
be " not guilty by reason of insanity," if the killing was the offspring
or product of mental disease in the defendant.
Neither delusion, nor knowledge of right and wrong nor design
nor cunning in planning and executing the killing and escaping or
1 Accord: P. v. Owens, 123 Cal., 482 (1899) ; Spencer v. St., 69 Md.,
28 (1888) ; St. V. Scott, 41 Minn., 365 (1889) ; Cunningham v. St., 56 Miss.,
269(1879); Mackin v. St., 59 N. J. L., 495 (1896) ; P. v. Carpenter, 102
N. Y., 238 (1886); St. V. Potts, 100 N. C, 457 (1888) ; St. v. Levelle, 34
S. C, 120(1890); Johnson •w. St., 100 Tenn., 254(1898); Cannon v. St.,
56 S. W., (Tex.) 351 (1900).— Ed.
276 Cases on Criminal Law.
avoiding detection, nor ability to recognize acquaintances, or to
labor, or transact business, or manage affairs, is, as a matter of law,
a test of mental disease ; but all symptoms and all tests of mental
disease are purely matters of fact, to be determined by the jury.
Whether the defendant had a mental disease, and whether the
killing of his wife was the product of such disease, are questions of
fact for the jury.
Insanity is mental disease — disease of the mind. An act pro-
duced by mental disease is not a crime. If the defendant had a
mental disease which irresistibly impelled him to kill his wife — if
the killing was the product of mental disease in him — he is not
guilty ; he is innocent — as innocent as if the act had been produced
by involuntary intoxication, or by another person using his hand
against his utmost resistance. Insanity is not innocence unless it
produced the killing of his wife.
If the defendant had an insane impulse to kill his wife, and
could have successfully resisted it, he was responsible. Whether
every insane impulse is always irresistible, is a question of fact.
Whether in this case the defendant had an insane impulse to kill
his wife, and whether he could resist it, are the questions of fact.
Whether an act may be produced by partial insanity when no
connection can be discovered between the act and the disease is a
question of fact.
The defendant is to be acquitted on the ground of insanity,
unless the jury are satisfied beyond a reasonable doubt that the
killing was not produced by mental disease.
The defendant was sentenced and filed this bill of exceptions.
Ladd, J.^ The remaining and most important questions in the
case arise upon the instructions given by the court to the jury, and
the refusal to give instructions requested by defendant's counsel.
When, as in this case, a person charged with crime admits the
act, but sets up the defence of insanity, the real ultimate question
to be-determined seems to be whether, at the time of the act, he
had the mental capacity to entertain a criminal intent — whether, in
point of fact, he did entertain such intent.
In solving that problem, as in all other cases, it is for the
'Part of this opinion is omitted.
Cases on Criminal Law. 277
court to find the law, and for the jury to find the fact. The main
question for our consideration here is, what part of this difficult
inquiry is law, and what part fact.
It will be readily agreed, as said by Shaw, C. J., in Com. v.
Rogers, 7 Met. 500, that if the reason and mental powers of the
accused are either so deficient that he has no will, no conscience,
or controlling mental power, or if, through the overwhelming
violence of mental disease his intellectual power is for the time
obliterated, he is not a responsible agent, and of course, is not
punishable for acts which otherwise would be criminal.
But experience and observation show that, in most of the cases
which come before the courts, where it is sufficiently apparent that
disease has attacked the mind in some form and to some extent, it
has not thus wholly obliterated the will, the conscience, and men-
tal power, but has left its victim still in possession of some degree
■of ability in some or all these qualities. It may destroy, or it may
•only impair and becloud the whole mind ; or, it may destroy, or
only impair the functions of one or more faculties of the mind.
There seem to be cases where, as Erskine said in Hadfield's case,
reason is not driven from her seat, but where distraction sits down
upon it along with her, holds her trembling upon it, and frightens
iher from her propriety.
The term, partial insanity, has been applied to such cases by
writers and judges, from Lord Hale to Chief Justice Shaw,
where, as has been said, " the mind may be clouded and weakened,
but not incapable of remembering, reasoning, and judging"; audit
is here that the difficulty of the subject begins, and that confusion
and contradiction in the authorities make their appearance. " No
one can say where twilight ends or begins, but there is ample dis-
tinction between night and day." We are to inquire whether a
universal test has been found wherewith to determine, in all cases,
the line between criminal accountability and non-accountability —
between the region of crime and innocence — in those cases which
lie neither wholly in the darkness of night nor the light of day. If
such a test exists or it one can be found, it is of the utmost import-
ance that it be clearly defined and broadly laid down, so that when
it is given to a jury it may aid rather than confuse them. To
ascertain whether a rule has hitherto been found, we must look to
ihe authorities ; and so far as we have been able to examine them
278 Cases on Criminal Law.
the leading and familiar English cases and authorities are substan-
tially as follows :
Lord Hale said the mental capacity ordinarily possessed by a
child fourteen years old, was the test.
Mr. Justice Tracey, in Arnold's case (1723), said: "A
man must be totally deprived of his understanding and memory, so
as not to know what he is doing, no more than an infant, a brute,,
or a wild beast" ; 16 Howell's St. Tr., 764; — and the same doc-
trine, substantially, seems to have been acted on in Ferrer's case,
19 St. Tr., 947.
The next prominent case in the books is Hadfield's case ( 1 800);.,
and all Tdesire to say of that case, in this connection, is, that it
seems to stand by itself It was clear that Hadfield knew right from'
wrong ; it was clear that he knew the nature of the act he was
about to commit ; it was clear he manifested design, foresight, and
cunning in planning and executing it ; and it was clear he knew it
would subject him to punishment, which was, indeed, his motive in
committing it. The most that can be said of it is that everybody
saw he was insane, and that his insanity produced the act.
Next come three cases tried in the year 18 12, Parker's case,,
reported in ColHnson on Lunacy 477, Bowler's case, id. 6ji, and
Bellingham's case ; in each of which a more humane rule than that
of Mr. Justice Tracey was adopted, namely, that knowledge of
right and wrong, considered as abstract qualities, was the test ;,
although in Bowler's case Mr. Justice Le Blanc added a further test,
clearly suggested by and growing out of the facts of that particular
case, and designed to furnish the rule by which the jury should
be guided in deciding it, rather than by the formula in respect to
right and wrong, namely, that it was for the jury to determine
whether the prisoner was under any illusion in respect to the prose-
cutor, which rendered his mind, at the moment, insensible of the
nature of the act he was about to commit. And in Bellingham's
case Sir James Mansfield, C. J., took the extraordinary liberty of
changing the whole scope and meaning of the rule by telling the
jury, in addition, that "it must be proved beyond all doubt that, at
the time he committed the atrocidus act, he did not consider that
murder was a crime against the laws of God and nature."
It can hardly be contended that these three cases go far
towards establishing a rule ; for there is not much reason in calling
Cases on Criminal Law. 279
that a rule, which the judge at the trial may feel at liberty to
change, for the purpose of bringing about a conviction or acquittal,
according to his individual view of the facts appearing in the case
before him.
But these remarks of Mansfield, C. J., were approved by Lord
Lyndhurst in Rex v. Offord, 5 C. &P., 168 (1831), although he,
in the same breath, or at least in the same charge to the jury, laid
down another and a new test, which seems to be entirely incon-
sistent with the rule in Belhngham's case, namely, that the jury
must be satisfied, before they could acquit the prisoner on the
ground of insanity, that he did not know, when he committed the
act, what the effect of it, if fatal, would be with reference to the
crime of murder. This is not so clear as might be desired, but I
should suppose it would strike the average apprehension of a jury
as about equivalent to telling them that he must know that the
killing would be murder ; which is a qualification of the rule as
much in favor of life as Sir James Mansfield's was in favor of death.
In Reginat-. Oxford, 9 C. & P. 525 (1840), Lord Denman
charged the jury : " If some controlling disease was in truth the
acting power within him, which he could not resist, then he will not
be responsible. It is not more important than difficult to lay down
a rule by which you are to be governed *******_
On the part of the defence, it is contended that the prisoner was
non compos mentis, that is (as it has been said), unable to distingui.sh
right from wrong ; or, in other words, that from the effect of a dis-
eased mind he did not know at the time that the act he did was
wrong * * * * Upon the whole, the question will be,
whether all that has been proved about the prisoner at the bar shows
that he was insane at the time when the act was done ; whether the
evidence given proves a disease in the mind as of a person quite
incapable of distinguishing right from wrong. Something has been
said about the power to contract, and to make a will. But I think
those things do not supply any test. The question is, whether the
prisoner was laboring under that species of insanity which satisfies
you that he was quite unaware of the nature, character and conse-
quences of the act he was committing, or, in other words, whether
he was under the influence of a diseased mind, and was wholly
unconscious at the time he was committing the act that it was a
crime."
28o Cases on Criminal Law.
But three years afterwards, in Regina v. Higginson, i Car &
Kir., 129, Mr. Justice Maule, apparently in utter disregard of the
elaborate charge of Lord Denman in Regina v. Oxford, said to the
jury : " If you are satisfied that the prisoner committed this offence,
but you are also satisfied by the evidence that at the time of the
committing of the offence the prisoner was so insane that he did
not know right from wrong, he should be acquitted on that ground ;
but, if you think that at the time of the offence he did know right
from wrong, he is responsible for his acts, although he is of weak
intellect." And again, in 1848, in Regina v. Stokes, the same
test, — knowledge of right and wrong in the abstract — was applied
by Baron Rolfe, who said : " Every man is held responsible for
his acts by the laws of his country, if he can discern right from
wrong."
The numerical preponderance of authority in England, as
gathered from the cases thus far, would seem to be decidedly in
favor of the rule that knowledge of right and wrong, without refer-
ence to the particular act, is the test ; although their force is much
shaken, if not wholly overthrown, by the qualifications which
judges have seemed to feel at liberty to introduce, to meet their
individual views, or the exigencies of particular cases ; and espe-
cially by the charge of Lord Denman in Regina v. Oxford.
The memorable effort of the House of Lords, in 1843, to have
the confusion and conflict of opinion which had arisen on this per-
plexing question all cleared away by one distinct and full avowal by
the judges of what the law was and should be in relation to it, is
too conspicuous in the history of the subject to be passed without
notice.
It may safely be said that the character of the judges, and the
circumstances under which the questions in McNaghten's case
(see note to Regina v. Higginson, i Car, & Kir., at p. 130) were
propounded to them by the House of Lords, make it morally cer-
tain that if, in the nature of things, clear, categorical, and consistent
answers were possible, such answers would have been given. In
other words, that if a safe, practical, legal test exists, it would have
been then found by those very learned men, and declared to the
world. Such a result would have brought order out of chaos, and
saved future generations of lawyers and judges a vast amount of
trouble in trying this kind of cases. But an examination of the
Cases on Criminal Law. 281
answers given shows that they failed utterly to do any such thing ;
and it is not too much to say that, if they did not make the path
to be pursued absolutely more uncertain and more dark, they at
best shed but little light upon its windings, and furnish no plain or
safe clue to the labyrinth.
In answer to the first question, all the judges, except Maule,
say that " notwithstanding the party accused did the act complained
of with a view, under the influence of insane delusion, of redressing
or revenging some supposed grievance or injury, or of producing
some public benefit, he is nevertheless punishable, according to the
nature of the crime committed, if he knew at the time of commit-
ting such crime that he was acting contrary to law, by which is
meant the law of the land." Here is an entirely new element —
knowledge that he was acting contrary to the law of the land ; and
hereupon the inquiry arises, is a man, acting under a delusion of
this sort, presumed to know the law of the land ? The answer
must be, yes ; for the judges say, further on : " The law is admin-
istered upon the principle that every one must be taken conclu-
sively to know the law of the land, without proof that he does
know it."
Let this proposition be examined a moment. Knowledge that
the act was contrary to the law of the land is here given as a test ;
that is, such knowledge is assumed to be the measure of mental
capacity sufficient to entertain a criminal intent. By what possible
means, it may be asked, can that test or measure be applied, with-
out first finding out whether the prisoner, in fact, knew what the law
of the land was? How could a jury say whether a man knew, or
did not know, that an act was contrary to the law of the land, with-
out first ascertaining whether he knew what that law was ?
It was like saying that knowledge of some fact in science, —
as, for example, that a certain quantity of arsenic taken into the
stomach will produce death, — shall be the test, and at the same
time saying that it makes ho difference whether the prisoner ever
heard of arsenic, or knows anything of its properties or not.
Knowledge that the act is contrary to law might be taken as a
measure of capacity to commit crime, and so might knowledge of
any other specific thing that should be settled upon for that pur-
pose ; and such a test would be consistent and comprehensible,
whether it were right or not ; but when it is said that knowledge of
282 Cases on Criminal Law.
a certain thing is the test, and then we are told in the next para-
graph that it makes no difference whether the man ever heard of
the thing or not, I confess that I am not able to see any opening
for escape out of the maze into which we are led. Whether a jury-
would be more successful, must depend, I suppose, on their com-
parative intelligence.
In connection with this rule, it is useful to bear in mind that
Hadfield knew he was doing an illegal act, and did it for the
avowed purpose of bringing upon himself the punishment which he
knew was the legal consequence of the act.
Maule, J., holds that the general test of capacity to know
right from wrong in the abstract, is to be applied in the case sup-
posed by the first question, the same as in any other phase of men-
tal unsoundness.
In answer to the second and third questions which relate to
the terms in which the matter should be left to the jury, the judges
say that "to establish a defence on the ground of insanity, it must
be clearly proved that, at the time of committing the act, the party
accused was laboring under such a defect of reason from disease of
the mind as not to know the nature and quality of the act he was
doing, or, if he did know it, he did not know he was doing what
was wrong."
Suppose now, an insane man does an act which he knows to
be contrary to law, because from an insane delusion (if that term
amounts to anything more than the single term insanity) he believes
it to be right notwithstanding the law, that the law is wrong, or
.that the peculiar circumstances of the case make it right for him to *
disregard it in this instance : how are these two rules to be recon-
ciled ? It would seem to be plain that they are in hopeless conflict,
and cannot both stand.
Maule J., says. " The questions necessarily to be submitted to
thejury are those questions of fact which are raised on the record.
In a criminal trial the question commonly is, whether the accused
be guilty or not guilty ; but in order to assist the jury in coming
to a right conclusion on this necessary and ultimate question, it is
usual and proper to submit such subordinate or intermediate ques-
tions as the course which the trial has taken may have made con-
venient to direct their attention to. What these questions are, and
the manner of submitting them, is matter, of discretion for the
Cases on Criminal Law. 285,
judge, — a discretion to be guided by a consideration of all the cir-
cumstances attending the inquiry. In performing this duty, it is
sometimes necessary or convenient to inform the jury as to the
law " — which, he repeats, is knowledge of right and wrong. He
also says there are no terms which the judge is by law required to
use, only they must not be inconsistent with the law that knowl-
edge of right and wrong is the test.
The answer to the fourth question introduces a doctrine which
seems to me very remarkable to say the least. The question was :
" If a person, under an insane delusion as to existing facts, com-
mits an offence, is he thereby excused ?" To which the answer
was as follows : " On the assumption that he labors under partial
delusion only, and is not in other respects insane, he must be con-
sidered in the same situation, as to responsibility, as if the facts,
with respect to which the delusion exists, were real. For exam-
ple : if, under the influence of delusion, he supposes another man to
be in the act of attempting to take away his life, and he kills that
man, as he supposes, in self-defence, he would be exempt from pun-
ishment. If his delusion was, that the deceased had inflicted a
serious injury to his character or fortune, and he killed him in re-
venge for such supposed injury, he would be liable to punishment."
The doctrine thus promulgated as law has found its way intO'
the text books, and has doubtless been largely received as the
enunciation of a sound legal principle since that day. Yet it is-
probable that no ingenious student of the law ever read it for the
first time without being shocked by its exquisite inhumanity. It
practically holds a man confessed to be insane, accountable for the
exercise of the same reason, judgment, and controlling mental power,,
that is required of a man in perfect mental health. It is, in effect, say-
ing to the jury, the prisoner was mad when he committed the act,
but he did not use sufficient reason in his madness. He killed a
man because, under an insane delusion, he falsely believed the man
had done him a great wrong, which was giving rein to a motive of
revenge, and the act is murder. If he had killed a man only
because, under an insane delusion, he falsely believed the man
would kill him if he did not do so, that would have been giving rein
to an instinct of self-preservation, and would not be crime. It is
true, in words, the judges attempt to guard against a consequence
so shocking, as that a man niay be punished for an act which is
284 Cases on Criminal Law.
purely the offspring and product of insanity, by introducing the
qualifying phrase, " and is not in other respects insane." That is,
if insanity produces the false belief, which is the prime cause of the
act, but goes no further, then the accused is to be judged accord-
ing to the character of motives which are presumed to spring up
out of that part of the mind which has not been reached or affected
by the delusion or disease. This is very refined. It may be
that mental disease sometimes takes a shape to meet the provisions
of this ingenious formula; or, if no such case has ever yet existed,
it is doubtless within the scope of omnipotent power hereafter to
strike with disease some human mind in such peculiar manner that
the conditions will be fulfilled ; and when that is done, when it is
certainly known that such a case has arisen, the rule may be appHed
without punishing a man for disease. That is, when we can certainly
know that, although the false belief on which the prisoner acted was
the product of mental disease, still, that the mind was in no other
way impaired or affected, and that the motive to the act did cer-
tainly take its rise in some portion of the mind that was yet in per-
fect health, the rule may be applied without any apparent wrong.
But it is a rule which can be safely applied in practice, that we are
seeking ; and to say that an act which grows wholly out of an
insane behef that some great wrong has been inflicted, is at the
same time produced by a spirit of revenge springing from some
portion or corner of the mind that has not been reached by the dis-
ease, is laying down a pathological and psychological fact which no
human intelligence can ever know to be true, and which, if it were
true, would not be law, but pure matter of fact. No such distinc-
tion ever can or ever will be drawn in practice; and the absurdity as
well as inhumanity of the rule seems to me sufficiently apparent
without further comment.
To form a correct estimate Of the value of these answers, we
have only to suppose that, at the end of a criminal trial where the
defence is insanity, they be read to the jury for their guidance in
determining the question with which they are charged. Tried by
this practical test, it seems to me, they utterly fail ; and the reason
of the failure, as I think, is, that it was an attempt to lay down as
law that which from its very nature, is essentially matter of fact.
It is a question of fact whether any universal test exists, and it is
also a question of fact what the test is, if any there be.
Cases on Criminal Law. 285
The efforts of text writers to extract a rule fiom the cases have
not, in my judgment, been more successful. See i Russ. Cr, 13;
Roscoe's Cr., Ev. 944. It is worthy of notice, however, that Mr.
Chitty lays down a rule from which is excluded all reference to
knowledge of right and wrong, or moral good and evil, thus :
"Where there is only such partial derangement as leaves the
party free to act or to forbear in the particular case in question, or
where he is guilty of the crime during a lucid interval, he will be
equally liable to punishment with those who are perfectly sane.
Where, however, the mind labors under such a delusion that though it
discerns some objects clearly, it is totally deranged as to the objects
of its attack, the party will be entitled to be acquitted." i Ch. Cr.
L., 725. To my mind this is but another form of saying that where
the act is the product of mental disease it is not crime ; which was
the instruction given in this case.
If we leave the English rule where it seems to be left by these
authorities, I think an examination of the American cases will not
lead to any more satisfactory result.
In Commonwealth v. Rogers, 7 Met, 500 (1844), Shaw, C. J.,
instructed the jury that " a person is not responsible for any crimi-
nal act he may commit, if, by reason of mental infirmity, he is
incapable of distinguishing between right and wrong in regard to the
particular act, and of knowing that the act itself will subject him
to punishment; or has no will, no conscience, or controlling men-
tal power ; or has not sufficient power of memory to recollect the
relations in which he stands to others, and in which they stand to
him ; or has his reason, conscience, and judgment so overwhelmed
by the violence of disease as to act from an uncontrollable impulse."
Here seem to be four distinct tests. The first is substantially
that given by Lord Denman in Regina v. Oxford, but with one
most important qualification added, namely, kriowledge that the
act will subject him to punishment. But how can it be said that
such knowledge constitutes one of the links in a chain of conclu-
sive evidence, — that it is one fact in a chain of facts from which
that degree of insanity which will excuse a person from crime is to
be conclusively found ?
If that be so, then certainly, a legal quality, effect, or signifi-
cance is given to it by its position in the chain, which no one
would ever think it possessed when standing alone. The desire for
■286 Cases on Criminal Law.
revenge may be so strong as to outweigh the fear of a punishment
which a man without any mental disease knows must follow his
■act. But the rule is, that, in addition to the knowledge of right
and wrong in respect to the particular act, the accused must have
been capable of knowing that the act itself would subject him to
punishment.
It is doubtless true that ability to know that a certain act will
be followed by punishment, furnishes evidence of the mental con-
dition. So would knowledge of any other fact in law or science.
But I can see no more reason for holding that such knowledge is
any part of a legal test of capacity to commit crime, than for holding
that knowledge of the cause of an eclipse is entitled to the same
effect.
The second rule relates to a case where there can be no
doubt, — where the will, the conscience, and controlling mental
power are all gone ; and the fourth is substantially the same, —
where the reason, conscience, and judgment are so overwhelmed
by the violence of disease, that he acts from uncontrollable impulse.
There can be no very appreciable legal distinction between a person
who has no will, no conscience, or controlling mental power, and
one whose reason, conscience, and judgment are so overwhelmed
by the violence of disease as to act from an uncontrollable impulse.
In both cases it is an act in which reason, conscience, judgment,
and will do not participate ; in a word, it is the product of mental
disease.
Power of memory sufficient to recollect the relations in which
he stands to others and in which others stand to him, which is
given as the third test, seems to me no more a legal criterion, than
power of memory to recollect any other fact which a healthy mind
would be expected to remember ; and such power of memory or
its lack, would be a fact, like other facts, for the jury to weigh in
judging whether he had the mental capacity to entertain a criminal
intent.
There is no doubt but these instructions of the learned and
eminent Chief Justice of Massachusetts have been largely followed
in cases since tried in this country ; but the course has been by no
means uniform, as we shall see.
In New York and Pennsylvania in the two leading cases of
Freeman v. People, 4 Denio 9, and Commonwealth v. Mosler, 4
Cases on Criminal Law. 287
Barr., 267, capacity to distinguish right from wrong was given as
the naked test. But in neither of those States has the rule thus
laid down been followed with uniformity. In the trial of Hunt-
ington, for forgery, in New York city, in 1856, Judge Capron said
to the jury : " To constitute a complete defence, insanity, if partial,
as monomania, must be such in degree as to wholly deprive the
accused of the guide of reason in regard to the act with which he
is charged, and of the knowledge that he is doing wrong in com-
mitting it." And the remarks of Edmonds, J., in the earlier case
•of The People z/. Kleim, i Edm. S. Cas., 13, are wholly at war with
any such rule as that promulgated in People v. Freeman. He
says : " The moral as well as the intellectual faculties may be so
■disordered by the disease as to deprive the mind of its controlling
and directing power ; — that he must know the act to be wrong and
punishable, and be able to compare and choose between doing it
and not doing it."
In Pennsylvania, in Commonwealth v. Knepley (1850), knowl-
edge of right and wrong in regard to the particular act was given
as the test ; and in Commonwealth v. Haskell, the judge charged
that " the true test lies in the word power. Has the defendant in
a criminal case the power to distinguish right from wrong, and the
spower to adhere to the right and avoid the wrong? "
It would probably not be far out of the way to say that the
number of American cases where knowledge of right and wrong
in the abstract, and knowledge of the nature and quality of the
act, — that it was wrong, — have been given as the test, is about
•equal, with a tendency of late years to the latter form ; while it
will appear that, in almost every case where any rule has been
j;iven on the subject, it has been modified and explained to meet
the facts of the particular case, or to carry out the personal views
•of the judge on the matter of insanity.
But there are not wanting cases where all tests have been
^discarded. In State v. Felter, 25 Iowa, 67, Dillon, C. J., says :
" The jury, in substance, should be told that if the defendant's act
in taking the life of his wife was caused by mental disease or
unsoundness, which dethroned his reason and judgment with
^respect to that act, which destroyed his power rationally to com-
prehend the nature and consequences of that act, and which,
.ov^erpowering his will, irresistibly forced him to its commission,
288 Cases on Criminal Law.
then he is not amenable to legal punishment. But if the jury
believe, from all the evidence and circumstances, that the defendant
was in possession of a rational intellect and sound mind, and
allowed his passions to escape control, then, though passion may
for the time being have driven reason from her seat and usurped
it, and have urged the defendant, with a force at the moment
irresistible, to desperate acts, he cannot claim for such acts the
protection of insanity." And in Stevens v. The State of Indiana,
reported in the Am. Law Reg., Sept., 1870, which was an indict-
ment for murder, and the defence insanity, an instruction to the
jury that, if they believed the defendant knew the difference
between right and wrong in respect to the act in question, if he
was conscious that such act was one which he ought not to do, he
was responsible, was held erroneous.
In the course of his opinion in that case, Gregory, J., speak-
ing of the charge in Commonwealth v. Rogers, said : " It is by no
means clear, and we think it is not entitled to the weight usually
awarded it."
Very much to the same effect was State v. Spencer, i Zabris-
kie, 196. HoRNBLOWER, C. J., said : " In my judgment the true
question to be' put to the jury is, whether the prisoner was insane
at the time of committing the act ; and in answer to that question
there is little danger ,of a jury's giving a negative answer,
and convicting a prisoner who is proved to be insane on the
subject matter relating to or connected with the criminal act, or
proved to be so far or so generally deranged as to render it difficult
or almost impossible to discriminate between his sane and insane
acts."
And, also, a case said to have been tried in York county,
Maine, in 1836, where the court charged the jury that if they were
satisfied that the prisoner was not of sound memory and discretion
at the time of committing the act, they were bound to return a
verdict of acquittal. Ray, Med. Jurisp. Ins., § 42. To the same
effect, also, are our own cases of Prescott and Corey, referred to by
the attorney-general in his brief
Professor Greenleaf adopts the charge of Chief Justice Shaw,
in Rogers' case, without any attempt at modification or explanation,
as covering the whole subject, so far as criminal responsibility is con-
cerned. 2 Gr. Ev., § 372.
Cases on Criminal Law. 289
Mr. Bishop undertakes to give the forms in which courts have
put the question of insanity to the jury in most of the modern
cases. I Bish. Cr. L., 475. But I have not been able to find a
cage, ancient or modern, where the judge did actually give the
question of insanity to the jury in just the terms of Mr. Bishop's
form ; and he says, speaking of his rule : " This form of stating
the question of insanity to the jury is well in cases where it is
admitted that the mental disease or imperfection extends only to
the intellectual powers, and the party has full control of his actions.
How numerous comparatively these cases are is matter of science
and fact nowhere to be discussed." Id., § 478.
In regard to the difficulties of the subject the same author says :
" The labors of writers on insanity have been exhausted in attempts
to find some test of ready application to determine when a person
is to be deemed insane, and when not, in reference to his responsi-
bility for crime. And judges, less informed on this subject than on
most other subjects of legal science, have struggled under the inher-
ent embarrassments of the question itself, under the influence of
erroneous notions in the community, and under the failures of coun-
sel and witnesses in particular cases to present the real points of
inquiry. The result has been, that instructions given in reference
to particular facts appearing in the cases before them have seemed,
to casual observers, to be very discordant, while to scientific inquir-
ers after the fact of insanity, they have seemed very absurd," Id.,
§ 474. And in a note, " It seems to me there has been too much
attempt to do what in its nature is impossible, and too little attempt
to do what is possible regarding this matter. It is not, I submit,
possible, in the nature of things, that the court should find an exact
and literal rule which may be put into the hand of a juryman where-
with to measure the mind and determine whether it is criminally
responsible or not for its act."
It is to be remarked that the same thing, in substance, was
admitted by the judges in McNaghten's Case. Tindal, C. J., giv-
ing the opinion of the majority, said : " We have forborne enter-
ing into any particular discussion upon the questions, from the
extreme difficulty of applying those answers to cases in which the
facts are not brought judicially before us. The facts of each par-
ticular case must, of necessity, present themselves with endless
variety and with every shade of difference in each case, and we
290 Cases on Criminal Law.
deem it at once impracticable, and dangerous if it were practicable,
to attempt to make minute applications of the principles involved
in the answers to your Lordships' questions."
Maule, J., speaking for himself, observed : " I feel great diffi-
culty in answering the questions put by your Lordships on this
occasion. First, because they do not appear to arise out of, and
are not put in reference to, a particular case or for a particular pur-
pose, which might explain or limit the generality of their terms, so
that full answers to them ought to be applicable to every possible
state of facts not inconsistent with those assumed in the ques-
tions."
It is entirely obvious that a court of law undertaking to lay
down an abstract general proposition, which may be given to the
jury in all cases, by which they are to determine whether the pris-
oner had capacity to entertain a criminal intent, stands in exactly
the same position as that occupied by the English judges in attempt-
ing to answer the questions propounded to them by the House of
Lords in this case ; and whenever such an attempt is made I think
it must always be attended with failure, because it is an attempt to
find what does not exist, namely, a rule of law wherewith to
solve a question of fact.
This is the only conclusion I desire to draw from the cases
and text writers referred to. It is clear to me that judges have
adapted their language to the facts of the particular case before
them ; and that when anything is said about knowledge of right
and wrong, or knowledge of the quality of the act, or any other
legal test, it has been, and will inevitably continue to be, qualified
and explained in such a way, to meet the evidence upon which the
jury are to pass, that its character as a rule entirely disappears.
No one but the Creator of all things can look in upon the
chaos of a disordered mind, and determine with certainty whether
its powers are so much prostrated, enfeebled, or deranged, that the
unhappy sufferer has ceased to be an accountable being. Still the
court and jury must determine that question, approximately, as
best they can in each individual case ; and it makes no difference,
so far as I can see, with the difficulty of the subject, whether Lord
Brougham's view, that a distinction is to be made between the
moral accountability of a man to his Maker and his accountability
to human tribiinals, be accepted or not. With this duty to perform,
Cases on Criminal Law. 291
and this responsibility upon them, courts naturally and properly
turn to men of science, such as have had large experience in the
care and treatment of the insane, for aid ; and the questions allowed
to be put to experts and answered by them, both in England and
this country show that what is laid down as laW in theory, is almost
universally treated as fact in practice.
At the trial where insanity is set up as a defense, two questions
are presented : First : Had the prisoner a mental disease? Sec-
ond : If he had, was the disease of such a character, or was it so
far developed, or had it so far subjugated the powers of the mind
as to take away the capacity to form or entertain a criminal intent ?
The first is so purely a question of fact, that no one would think of
disputing it any sooner than he would dispute that it was a ques-
tion of fact whether a man has consumption or not. It is in set-
tling the second that all the difficulty arises.
The instructions asked for in this case go upon the ground
that this is a mixed question of law and fact ; that where there is
delusion there can be no criminal intent ; and that, where there is
capacity to know right from wrong in reference to the particular
act, there is capacity to commit crime. It is true the sixth request
does not present the matter in just this form ; but if knowledge of
right and wrong, as to the act, is to be considered a legal test of
criminal accountability, it must follow that those who have such
knowledge are accountable, as well as that those who have it not are
not accountable. And this court is now called on, as a court of
law, to decide whether either of these tests shall be adopted in this
State ; and if so, which.
It would doubtless be convenient to adopt some such test. It
would, to some extent, save the trouble of trying each case, as it
arises on its own special' and peculiar facts ; at any rate, it would
narrow the range of investigation to a search for the facts consti-
tuting the test adopted. But in cases of this sort, the argument of
convenience is not to be admitted. No formal rule can be applied
in settling questions which have relation to liberty and life, merely
because it will lessen the labor of the court or jury. Nor ought
such a rule to be adopted upon the authority of cases, unless those
cases show beyond a doubt not only its existence, but that it is
founded in reason and fundamental truth. Expressions of even
the most eminent judges must not be mistaken for the enunciation
292 Cases on Criminal Law.
of a universal principle of law, when it appears that they were used
in charging the jury upon the facts arising in a particular case.
The instructions given also imply that this is a mixed question
of law and fact ; that the only element of law which enters into it
is that no man shall be held accountable, criminally, for an act
which was the offspring and product of mental disease. Of the
soundness of this proposition there can be no doubt. Thus far all
are agreed ; and the doctrine rests upon principles of reason, human-
ity and justice too firm and too deeply rooted to be shaken by any
narrow rule that might be adopted on the subject. No argument
is needed to show that to hold that a man may be punished for
what is the offspring of disease would be to hold that he may be
punished for disease. Any rule which makes that possible cannot
be law.
It will hardly be contended, I suppose, that delusion or knowl-
edge of right and wrong with reference to the act, or any other
thing, can, with any degree of propriety, be called a legal test of
the mental capacity to commit crime, unless that capacity is deter-
mined absolutely, in all cases, by the presence or absence of the
fact which is assumed to constitute the test.
If we speak of delusion, for instance — before that can be
adopted as the test in the sense intended by the request in this case
it must appear that it makes no difference whether the delusion has
any reference to or connection with the act or not. If we say, as
Erskine said in Hadfield's case, that delusion is the test when it
appears to have produced the act, but not when it does not appear
to have produced the act — that the delusion and the act should be
connected — we admit that delusion cannot be a legal test, because
it is not a universal test.
And even if it were established, that in all cases where there is
delusion there is not capacity to commit crime, with as much cer-
tainty as that a heavy body left free in the air will fall to the earth,
it still remains a fact. That a heavy body will fall is a fact, although
it is at the same time a law of nature ; that delusion attends inca-
pacity for crime would be a fact still, although were the fact ascer-
tained to be certain and universal, it might be called a law of men-
tal disease, and might, therefore, be given to the jury as a criterion
without any positive or practical wrong.
Yet, in that view, it would be the law of the land in no other
Cases on Criminal Law. 293
sense than the laws of nature and physics may be considered laws
of the land. Now, this court, sitting for the decision of questions of
law, is not at liberty to receive and consider evidence or weigh and
determine matters of fact.
But the very first step in the inquiry to ascertain if there be any
test or criterion that may be safely given to the jury on this subject,
whether as a fact universally true, or as a principle of law, involves
the examination of an immense mass of evidence, as complicated
and difficult to understand as can well be conceived. Moreover, it
would require a degree of skill and scientific attainment which could
only be reached by years of special study and intelligent observa-
tion. Not only ought all the facts bearing on the question to be
collected from every asylum for the insane throughout the world,
but, as an inflexible rule is to be established, the facts of all other
cases where the patient has never received scientific treatment
ought to be added to the stock. Then, after collecting the facts
in this way, it would be necessary to compare cases and classes of
cases one with the other, to weigh facts against facts, to balance
theories and opinions, and finally to deduce a result which might
itself turn out to be nothing more than a theory or opinion after
all. At any rate it would be a deduction of fact.
It need not be said that this is not the business of a court of
law.. It is a work which can only be reasonably well done by men
who devote their lives exclusively to its accomplishment. Such
a work has doubtless been done, with extraordinary patience and
ability, by our distinguished countrymen, Dr. Ray ; and the result
of his laborious investigation is, that no test can be found. He says :
" To persons practically acquainted with the insane mind, it is well
known that in every hospital for the insane are patients capable of
distinguishing between right and wrong, knowing well enough how
to appreciate the nature and legal consequences of their acts,
acknowledging the sanctions of religion, and never acting from
irresistible impulse, but deliberately and shrewdly." Ray's Med.
Jurisp. Ins. § 43.
If we were at liberty to weigh and consider evidence upon the
question, it is clear that such testimony must outweigh ail the con-
venient formulas and arbitrary dogmas laid down by lawyers and
judges from the time of Lord Hale to the present, simply for the
reason that Dr. Ray is qualified by study and observation to give
294 Cases on Criminal Law.
an opinion, while lawyers and judges are not. But we do not
consider evidence upon this point at all. Whether there is any
universal test, is as clearly a pure matter of fact, as is the question
what that test may be.
In view of these considerations, we are led to the conclusion
that the instruction given to the jury in this case, that "If the
defendant killed his wife in a manner that would be criminal and
unlawful if the defendant were sane, the verdict should be ' not
guilty by reason of insanity,' if the killing was the offspring or
product of mental disease in the defendant," was right; that it
fully covers the only general, universal element of law involved in
the inquiry ; and, therefore, that any further step in the direction
indicated by the requests would have been an interference with the
province of the jury, and the enunciation of a proposition which, in
its essence, is not law, and which could not in any view safely be
given to the jury as a rule for their guidance, because, for ought
we can know, it might have been false in fact.
This would seem to dispose of the whole case. All the other
instructions given are only the direct logical consequence of this
principle.
Whether the defendant had a mental disease, as before
remarked, seems to be as much a question of fact as whether he
had a bodily disease ; and whether the killing of his wife was the
product of that disease, was also as clearly a matter of fact as
whether thirst and a quickened pulse are the product of fever.
That it is a difficult question does not change the matter at all. The
difficulty is intrinsic, and must be met from whatever direction it
may be approached. Enough has already been said as to the use
of symptoms, phases, or manifestations of the disease as legal tests
of capacity to entertain a criminal intent. They are all clearly
matters of evidence, to be weighed by the jury upon the question
whether the act was the offspring of insanity ; if it was, a criminal
intent did not produce it ; if it was not, a criminal intent did pro-
duce, and it was crime.
The instructions as to insane impulse seem to be quite correct,
and entirely within the same principle. If the defendant had an
insane impulse to kill his wife, which he could not control, then
mental disease produced the act. If he could have controlled it,
then his will must have assented to the act, and it was not caused
Cases on Criminal Law. 295
by disease, but by the concurrence of his will, and was therefore
crime.
These instructions have now been twice given to the jury in
capital cases in this State — first, by Chief Justice Perley, in State
V. Pike, and now again by Judge Doe, in the case before us. In
State V. Pike no exceptions were taken to this part of the charge,
and the questions here raised were not before the whole court for
judicial determination, although they were printed in the case as
transferred, and no objection to their form is understood to have
been made.
But a question was passed upon in that case, which, carried
to its logical results, goes far towards settling most of the questions
raised upon the instructions here. It was claimed that the defend-
ant was irresponsible by reason of a species of insanity called
dipsomania. The court instructed the jury that "whether there is
such a mental disease as dipsomania, and whether the defendant
had that disease, and whether the killing of Brown was the product
of such disease, were questions of fact for the jury." These
instructions were specially excepted to by the defendant, and were
held correct. This would seem to be entirely inconsistent with the
idea that either delusion or knowledge of right and wrong is, as
matter of law, a test of criminal capacity ; and would also seem to
be about equivalent to holding, in general terms, that it was for the
jury to say whether the killing was the product of mental disease,
and return their verdict of " guilty," or "not guilty by reason of
insanity," as they found that fact to be.
We should be slow to establish any doctrine on this important
subject, which we could see would be likely to result in the escape
of malefactors from punishment, or afford encouragement to a ficti-
tious defence of insanity ; and no considerations of convenience
or ease in the administration of the law, as before observed, should
be allowed to weigh at all against adhering to any doctrine or
any course of practice that rests upon sound reason, or that
appears to be necessary for the attainment of right results, whether
such doctrine or practice is supported by uniform authority
or not.
Still it is no objection to the course of the judges who tried
this case, and who tried Pike's case, that it relieves the subject of
some of its most formidable difficulties so far as the court is
396 Cases on Criminal Law.
concerned, and, at the same time, furnishes at least one clear
and explicit direction which the jury can understand.
No untried or doubtful theory is adopted. The instruction
given was always law, and always must be law, while justice is
administered upon principles at all consonant with the calls of
civilization and humanity. The only objection is, that the court
did not go further, and undertake to explore a region where all is
doubt, uncertainty, and confusion upon the authorities, and where,
upon principle, they had no right to go at all ; that they did not
undertake to lay down a rule, where, if we could allow ourselves
to investigate the fact, we should probably find there is, and
can be, no rule, nor to enunciate as law a pure matter of fact which
can only be absolutely known to the Almighty.
I may add that it confirms me in the belief that we are right,
or at least have taken a step in the right direction, to know that
the view embodied in this charge meets the approval of men who,
from great experience in the treatment of the insane, as well as
careful and long study of the phenomena of mental disease, are
infinitely better qualified to judge in the matter than any court or
lawyer can be. See Ray's Medical Jurisp. Ins., 5th ed., § 44.
The satisfaction with which the charge to the jury in State v.
Pike is understood to have been received by the most enlightened
members of the medical profession, proves to my mind, not that
we have thrown down old landmarks to adopt any theory based on
a partial, imperfect, or visionary view of the subject, but that, in a
matter where we must inevitably rely to a great extent upon the
facts of science, we have consented to receive those facts as devel-
oped and ascertained by the researches and observation of our own
day, instead of adhering bhndly to dogmas which were accepted as
facts of science and erroneously promulgated as principles of law
fifty or a hundred years ago.
The last instruction, that the defendant was to be acquitted on
the ground of insanity unless the jury were satisfied beyond a
reasonable doubt that the killing was not produced by mental dis-
ease, was in accordance with State v. Bartlett, 43, N. H., 224, and
was correct.
Exceptions overrtded}
1 Accord : Parsons v. St., 81 Ala., 577 (1886). — Ed.
Cases on Criminal Law. 297
Sherwood, P. J., in St. v. Palmer, 61 S. W., 651 (1901),
" Though the defense in this case is weak-mindedness, or imbe-
cility, yet the same test — that of the ability to distinguish right
from wrong in the doing of the particular act — must be applied to
imbecility as well as to insanity."
CoFER, J., in Fain v. Commonwealth, 78 Ky., 183 (1879):
" All the modern medico-legal writers to whose writings we have
had access recognize a species of mental unsoundness, connected
with sleep, which they commonly treat of under the general head
of Somnambulism. * * * They define somnolentia ' to be the
lapping over of a profound sleep into the domain of apparent
wakefulness,' and say it produces a state of involuntary intoxica-
tion, which for the time destroys moral agency. * * * jf^ ^s
claimed, the appellant was unconscious when he fired the first shot,
it cannot be imputed to him as a crime. Nor is he guilty if par-
tially conscious, if, upon being partially awakened, and finding the
deceased had hold of him, and was shaking him, he imagined he
was being attacked, and believed himself in danger of losing his
life or of sustaining great bodily injury at the hands of his assail-
ant, he shot in good faith, believing it necessary to preserve his
life or his person from great harm. In such circumstances it does
not matter whether he had reasonable grounds for his belief or not."
INSANITY. {Continued.)
{b) Proof of Insanity.
ORTWEIN V. COMMONWEALTH.
Supreme Court of Pennsylvania, 1874.
76 Pennsylvania, 414.
Ernest Ortwein, alias Mentzger, was indicted for murder at the
June Term, 1874, of the Court of Oyer and Terminer of Allegheny
county.
The jury found the prisoner guilty of murder in the first
degree.
298 Cases on Criminal Law.
The prisoner took a writ of error, and assigned for error,
amongst other things, the answer of the court to his fifth point.^
Chief Justice Agnew dehvered the opinion of the court.
The chief question in this case arises under the fifth point of
the prisoner, which was negatived by the court below. It is this :
5. If the jury have a reasonable dou'bt of the sanity of the
prisoner at the time of the killing they cannot convict.
The industry of the able counsel of the prisoner has collected
and classified many cases on this point. While we think their
weight accords with our own conclusion, we cannot help perceiv-
ing, in their number and variety, that the decision of the question
should rest rather on a sound basis of principle than on the conclu-
sions of other courts. In order to apprehend the true force of the
principles to be applied, we must keep in the foreground the facts
of the case before any question of insanity can arise. Insanity is a
defence. It presupposes the proof of the facts which constitute a
legal crime, and is set up in avoidance of punishment. Keeping
in mind, then, that an act of wilful and mahcious killing has been
proved and requires a verdict of murder, the prisoner, as a defence,
avers that he was of unsound mind at the time of the killing, and
incapable of controlling his will, and, therefore, that he is not legally
responsible for his act. This is the precise view that the statute
itself takes of the defence, in declaring the duty of the jury in respect
to it. The 66th section of the Criminal Code of 31st of March,
i860, taken from the Act of 1836, provides : " In every case in
which it shall be given in evidence upon the trial of any person
charged with any crime or misdemeanor, that such person was
insane at the time of the commission of such offence, and he shall
be acquitted, the jury shall be required to find specially whether
such person was insane at the time of the commission of such
offence, and declare whether he was acquitted by them on the
ground of insanity." Thus the verdict must find the fact of insanity,
and that the acquittal is because the fact is so found. The law
then provides for the proper custody of the insane prisoner. This
being the provision of the statute, it is evident that a jury, before
finding the fact of insanity specially, must be satisfied of it by the
evidence. A reasonable doubt of the fact of insanity cannot, there-
1 Only so much of the case is printed as relates to proof of insanity.
Cases on Criminal Law. 299
fore, be a true basis of the finding of it as a fact and as a ground of
acquittal and of legal custody. To doubt one's sanity is not nec-
essarily to be convinced of his insanity. It has been said in a
nearly analogous case, " As to whether a reasonable doubt shall
establish the existence of a plea of self defence, I take the law to
be this : If there be a reasonable doubt that any offence has been
committed by the prisoner, it operates to acquit. But if the evi-
dence clearly establishes the killing by the prisoner, purposely, with
a deadly weapon, an illegal homicide of some kind is established,
and the burden then falls upon the prisoner, and not on the Com-
monwealth, to show that it was excusable as an act of self deence.
If, then, his extenuation is in doubt, he cannot be acquitted of all
crime, but must be convicted of homicide in some one of its grades —
manslaughter at least." Commonwealth v. Drum, 8 P. F. Smith,
22. Such also was the opinion of the late Chief Justice Lewis, a
most excellent criminal law judge, when president of the Lancaster
County Oyer and Terminer, in the trial of John Haggerty, in the
year 1847. Lewis' U. S. Criminal Law, p. 402. He said, p. 406 :
"The jury will decide upon the degree of intoxication, if any existed,
and upon the existence of insanity. The burden of proof of this
defence rests upon the prisoner ; the fact of killing under circum-
stances of deliberation detailed in this case being established, the
insanity which furnishes a defence must be shown to have existed
at the time the act was committed. The evidence must be such
as satisfies the minds of the jury." Thus, according to both statu-
tory and judicial interpretation, the evidence to establish insanity
as a defence must be satisfactory, and not merely doubtful.
If we now analyze the subject, we shall find that this is the
only safe conclusion for society, while it is just to the prisoner.
Soundness of mind is the natural and normal condition of men, and
is necessarily presumed, not only because the fact is generally so,
but because a contrary presumption would be fatal to the inter-
ests of society. No one can justly claim irresponsibility for his
act contrary to the known nature of the race of which he is
one. He must be treated and be adjudged to be a reasona-
ble being until a fact so abnormal as a want of reason
positively appears. It is, therefore, not unjust to him that he
should be so conclusively presumed to be until the contrary is
made to appear on his behalf. To be made .so. to appear to the
300 Cases on Criminal Law.
tribunal determining the fact, the evidence of it must be satisfac-
tory, and not merely doubtful, as nothing less than satisfaction can
determine a reasonable mind to believe a fact contrary to the course
of nature. It cannot, therefore, be said to be cruel to the prisoner
to hold him to the same responsibility for his act, as that to which
all reasonable beings of his race are held, until the fact is positively
proved that he is not reasonable. This statement derives additional
force from the opinion of Chief Justice Gibson, in the case of the
Commonwealth v. Mashler,^ tried before him and Justices Bell and
Coulter, in Philadelphia, and quoted from in Lewis' U. S. C. L.,
403-4. " Insanity," he says, "is mental or moral, the latter being
sometimes called homicidal mania, and properly so. A man may
be mad on all subjects, and then, though he may have a glimmer-
ing of reason, he is not a responsible agent. This is general
insanity ; but if it be not so great in its extent or degree as to
blind him to the nature and consequences of his moral duty, it is
no defence to an accusation of crime. It must be so great as
entirely to destroy his perception of right and wrong, and it is not
until that perception is thus destroyed that he ceases to be respon-
sible. It must amount to delusion or hallucination controlling his
will, making the commission of the act, in his apprehension, a duty
of overruhng necessity." Again : " Partial insanity is confined to
a particular subject, being sane on every other. In that species of
madness it is plain that he is a responsible agent if he were not
instigated by his madness to perpetrate the act. He continues to
be a legitimate subject of punishment, although he may be laboring
under a moral obliquity of perception, as much so as if he were
merely laboring under an obliquity of vision." And again : "The
law is, that whether the insanity be general or partial, the degree
of it must be so great as to have controlled the will of its subject,
and to have taken from him the freedom of moral action." Thus
all the utterances of the Chief Justice on this subject are positive
and emphatic, and allow no room for doubts, or merely negative
expressions.
And if this reasoning were even less than conclusive, the safety
of society would turn the scale. Merely doubtful evidence of
insanity would fill the land with acquitted criminals. The moment
^ S. C, nom., C. v. Mosler ; seesu/ira.
Cases on Criminal Law. 301
a great crime would be committed, in the same instant, indeed,
often before, would preparation begin to lay ground to doubt the
sanity of the perpetrator. The more enormous and horrible the
crime, the less credible, by reason of its enormity, would be the
evidence in support of it ; and proportionately weak would be the
required proof of insanity to acquit of it. Even now the humanity
of the criminal law opens many doors of escape to the criminal.
Then a wider door would be opened by the doubtful proof of
insanity, made still more open by the timidity of jurors, their loose
opinions on the subject of punishment, and their common error
that the punishment is the consequence of their finding of the truth
of the facts, instead of the consequence of the commission of the
crime itself. The danger to society from acquittals on the ground
of a doubtful insanity demands a strict rule. It requires that the
minds of the triers should be satisfied of the fact of insanity.
Finally, we think this point has been actually ruled by this court in
the case of Lynch v. Commonwealth, decided at Pittsburg in 1873.
The prisoner's second point was in these words : " That if the jury
had a reasonable doubt as to the condition of the defendant's mind
at the time the act was done, he is entitled to the benefit of such
doubt, and they cannot convict." The court below said in answer :
"The law of the State is that where the killing is admitted, and
insanity or want of legal responsibility is alleged as an excuse, it is
the duty of the defendant to satisfy the jury that insanity actually
existed at the time of the act, and a doubt as to such insanity will
not justify a jury in acquitting upon that ground." This ruHng
was sustained. Opinion by Read, C. J., See Pittsburg Legal
Journal, 14, 53.
The sentence of the Court of Oyer and Terminer is affirmed.*
1 Accord: Maxwell?'. St., 89 Ala., 150(1889); Boiling v. St., 54 Ark.,
588 (1891) ; P. V. Bemmerly, 98 Cal., 299 (1893); Fogarty v. St., 80 Ga.,
450(1888); P. V. Walter, l Idaho, 386 (1871); St. v. Trout, 74 Iowa, 545
(1888); Moorez/. C. 13 Ky. L. R., 738 (1892); St. v. Lawrence, 57 Me.,
574(1870); C. V. Rogers, 7 Met., 500 (1844); [but see C. z/. Heath, n
Gray, 303 (1858)]; St. v. Hanley, 34 Minn., 430(1886); St. v. Schaefer,
116 Mo., 96 (1893) ; St. V. Lewis, 20 Nev., 333 (1889) ; St. v. Davis, 109
N. C, 780 (1891); Bond V. St., 23 Ohio St., 349 (1872) ; St. v. Alexander,
30 S. C, 74 (1889) ; Leache v. St., 22 Tex. App., 279 (1886) ; P. v. Dillon,
8 Utah, 92 (1892) ; Baccigalupo 7/. C., 33 Gratt., 807 (1880) ; St. v. Strauder,
II W. Va.,745 (1877).— Ed.
302 Cases on Criminal Law.
STATE V. DeRANCE
Supreme Court of Louisiana, 1882.
34 Louisiana Annual, 1 86.
The defendants were indicted for murder and found guilty
of manslaughter and sentenced to imprisonment for five years from
which judgment they appealed, assigning as error the charge of
the court that it must be established beyond a reasonable doubt,
that there existed, on the part of the accused, no capacity to dis-
cern right from wrong as to the act forming the basis of the charge.
Unless the jury be satisfied in this respect, the presumption of san-
ity remains unshaken and needs no evidence in its support. "^
On appeal the court through Levy, J., Bermudez, J., taking
no part in the decision, affirmed the judgment.
On application for rehearing.
The opinion of the court was delivered by
Fenner, J. We have given much reflection and earnest con-
sideration to the learned brief for rehearing filed herein by counsel
for defendants, and especially to their views touching the law appli-
cable to insanity as a defense in criminal prosecutions.
The presumption of innocence and the presumption of sanity
are both embraced within the class of disputable presumptions of
law corresponding to the presumptiones Juris of the Roman Law,
which may always be overcome by opposing proof, i Greenl. Ev.,
§ 33 ; I Wharton Cr. L., § 707.
It cannot be sensibly urged that the presumption of san-
ity is the less powerful of the two, since it is the basis of
all human responsibility, the foundation of all law, and the
accepted guide of conduct in all the transactions and relations
of mankind. Experience certainly demonstrates that, in pros-
ecutions for crime, the presumption of innocence is rebutted a
thousandfold more frequently than the presumption of sanity,
and the application of any other test would not exhibit a dif-
ferent result. Inasmuch as human experience is the foundation of
presumptions, this would seem to indicate that the presumption of
sanity is the better founded and more powerful of the two. The
doctrine that, in criminal cases, the guilt of the accused must be
1 The statement of facts is abridged from the opinion of Levy, J.
Cases on Criminal Law. 303
established beyond a reasonable doubt, rests on no other reason
or principle than that such proof is necessary to overcome the pre-
sumption of innocence. Now, if, as we have shown, the presump-
tion of sanity is of like character, and of equal, if not superior
strength, why should it be overcome by a less degree of proof ?
It cannot be successfully maintained, that in criminal cases,
the presumption of sanity is neutralized or overcome, or nullified
by the presumption of innocence. The weight of authority is
overwhelming in favor of the doctrine, that, when the State has
established the corpus delecti in such manner, that the accused, if
sane, would be held guilty, the presumption of innocence is
rebutted, and the presumption of sanity comes into full operation,
to complete, by its own force, the case of the State ; and that, if
the accused relies upon the defense of insanity, the burden of
proof is thrown upon him and he must establish it by such proof
as will rebut the presumption of sanity.
The question upon which English and American courts are
mainly divided is as to the kind and degree of evidence required
to effect such rebuttal.
The question is not concluded by authority. Courts have
propounded three theories, viz :
I. That insanity, as a defense, must be proved beyond a rea-
sonable doubt. 2. That the jury are to be governed by the pre-
ponderance of evidence. 3. That the prosecution must prove
sanity beyond a reasonable doubt. Whart. Cr. L., § 55.
The last theory does not dommend itself to our judgment, is
supported, in its full extent, by few authorities, and is directly con-
trary to the jurisprudence of this court, as established in the only
case in which the subject was directly considered, and where it was
held, that, " when insanity is pleaded in defense of a criminal act,
it must be clearly shown that it existed at the time of the act," and
that " every person is presumed to be sane until the contrary is
proved, and it is for him who sets up this defense, to prove it by
evidence which will satisfy the minds of the jury that the party was
insane at the time of the commission of the offense." State v. Cole-
man, 27 A., 691.
The joint opinion of the judges of England, delivered to the
House of Lords, through Lord Chief Justice TindaLl, declared that
" the jury ought to be told, in all cases, that every man is presumed
304 Cases on Criminal Law.
to be sane and to possess a sufficient degree of reason to be respon-
sible for his crimes, until the contrary is proved to their satisfaction ;
and that to establish a defense on the ground of insanity, it must be
clearly proved," etc. McNaghten's case, lO Clark and Fin., 210.
The doctrine, in nearly the same words, is announced by Mr.
Greenleaf 2 Greenl. Ev. § 373.
In Bellingham's case it is said that Lord Mansfield instructed
the jury that insanity " ought to be proved by the most distinct
and unquestionable evidence, that, in fact, it must be proved
beyond all doubt, and that there was no other proof of insanity
that would excuse murder or any other crime."
In Oxford's case, Lord Lyndhurst told the juiy that " they
must be satisfied, before acquitting the prisoner, that he did not
know," etc., and then expressed his entire concurrence in the ob-
servations of Lord Mansfield, just quoted, i Russell on Cr., p. 9.
The English authorities are uniform to the effect, that in order
to sustain the defense of insanity, the jury must be satisfied that it
exists, and that the proof must be clear and convincing, and we do
not understand even the decision of Lords Mansfield and Lynd-
hurst to go further than this, being satisfied that they only meant
that the proof must be such as to exclude all reasonable doubt.
The Supreme Courts of Virginia, of Alabama, of Missouri, of
Massachusetts, of Pennsylvania,of Cahfornia, ofNew Jersey, and per-
haps other States, have all held in accordance with the doctrine of
this court in Coleman's case, that the burden of proof to rebut the
presumption of sanity, is on the defendant, and that insanity must be
proved affirmatively, fully, and clearly, and in such manner as to
satisfy the jury. It is true that several of the courts referred to,
qualify their expressions by saying, in effect, that though it must
be proved clearly and to the satisfaction of the jury, yet it need
not be proved beyond a reasonable doubt. The limitation is
entirely inconsistent with the original proposition. That which
leaves reasonable doubt in the mind, cannot be said to be clearly
proved. A mind vexed with reasonable doubts about a fact can-
not be satisfied as to the existence of such fact.
Proof beyond reasonable doubt means nothing more, in the
oft-quoted languageof Chief Justice Shaw, than " that the evidence
must establish the truth of the fact to a reasonable and moral cer-
tainty ; a certainty that convinces and directs the understanding
Cases on Criminal Law. 305
and satisfies the reason and judgment of those who are bound to
act conscientiously upon it." Webster's case, $ Cush., 320. As
said by another learned court : " AH that the law requires is moral
certainty, which is that the jury, whether the evidence be positive
or presumptive, should be satisfied. Giles v. State, 6 Geo., 276.
Hair splitting distinctions, under which some courts hold, that if
the jury entertain only a reasonable doubt of the insanity, they
must convict, but if they entertain reasonable doubt of the sanity
of the prisoner, they must acquit, do not commend themselves to
our judgment. Sanity and insanity are opposite conditions, exclu-
sive of each other. A reasonable doubt as to insanity is a reason-
able doubt as to sanity, and vice versa.
We can understand, that as to indifferent questions, not pri-
marily solved by any presumption of law, and which the jury must
solve, one way or the other, there may arise a state of mind, in
which, though not clearly convinced either way, the juror must
find in favor of that side which is least doubtful. But on a ques-
tion primarily, and until rebutted, conclusively solved by a power-
ful presumption of law, we cannot understand how a jury can be
justified in disturbing that existing status of legal satisfaction, upon
evidence which merely raises a doubt, however reasonable.
The doctrine that the jury must be governed by the prepon-
derance of evidence is vague, uncertain and unsatisfactory. The
only evidence on the question of sanity or insanity, found in the
case, might be evidence of the defendant, and although it might
not be sufficient to raise more than the most shadowy doubt, the
jury under this doctrine, might be required to acquit. If, on the
contrary, the presumption of sanity is to be considered as an ele-
ment of weight in favor of the State, we are then remitted to the
original question, as to what weight of contrary testimony will
constitute preponderance.
Much reflection has convinced us that the doctrine of the
English courts, and of this and other American courts which have
followed them, is most conformable to reason, principle and com-
mon sense.
The tendency of the opposite theory is, in our judgment, to
emasculate our system of criminal justice, and to send juries adrift
without any reliable chart or compass, upon a sea of doubt and
speculation.
3o6 Cases on Criminal Law.
The phenomena of the human mind are so mysterious, the
boundaries between its normal and abnormal conditions so shadowy,
the transports of frantic passion and the powerful impulses of
vicious tendencies are so nearly akin to temporary mental derange-
ment, that unless juries hold fast to the wholesome presumption
of sanity, responsibility for crime will be seriously impaired, and
society will lie at the mercy of evil disposed men, who, while too
sane to be confined in asylums, can yet raise a doubt as to
whether they are sane enough to be punished for crime.
We stand by the doctrine of this court in Coleman's case,
that insanity, when set up as a defense to a criminal charge, must
be " clearly shown by evidence which will satisfy the minds of the
jury that the party was insane at the time of the commission of
the offense" ; and we know of no definition of "proof beyond a
reasonable doubt," which is not fully covered by this statement.
Certainly in this case, the judge meant, and sufficiently informed
the jury that he meant, nothing more than this, because in other
parts of his charge he distinctly told the jury: "Should the men-
tal unsoundness of one or more of the accused at the time of
the commission of the offense, be established to the satisfaction of
the jury, you will acquit him or them," and again, " if you believe
that at the time of the act they are accused of, they were not in
such a mental condition as to create any responsibility on their
part, acquit them."
We remain satisfied of the soundness of the judge's rulings on
all points, and the rehearing is refused.^
CUNNINGHAM v. STATE.
Supreme Court of Mississippi, 1879.
56 Mississippi, 269.
Chalmers, J., delivered the opinion of the court.^
Adeline Cunningham was convicted, in the Circuit Court of
Clay county, of the murder of her husband, and sentenced to be
1 Accord: St. v. Spencer, 21 N. J. L. 196, (1846); St. v. Murray, 11 Ore.
413, {1884).— Eo.
2 Only so much of the opinion is given as relates to proof of insanity.
Cases on Criminal Law. 307
hung. That she committed the deed, and that it was one of pecu-
liar atrocity, is not denied nor gainsaid.
In the dead hour of the night, while the husband lay sleeping
on the common bed, she split open his head with a hatchet, without
provocation or motive, so far as can be ascertained. She waited
quietly till morning came, and then freely and voluntarily avowed
the act to all inquirers, offering no excuse, save that to one person
she stated that her husband was attempting to take her life with a
knife, which, she said, would be found in the bed, but which
nowhere could be discovered.
The defence set up for her is temporary or periodic insanity,
produced by derangement in her monthly menstruations, and
which, it is said, was liable to attack her at each recurring monthly
period.
Without desiring to express any opinion on the facts, it is
proper to say that there was sufficient evidence to suggest at least
a possibility of the truth of her defence, and to demand that the
jury should be left free to determine the question, unembarrassed
by erroneous instructions from the court.
They were not so left. By the first instruction given for the
State they were informed that " the legal presumption of sanity is
not overcome by the mere probability that the party was insane,
but will stand until overthrown by evidence. Mere probability of
insanity cannot prevail over the presumption of sanity, so as to
work the acquittal of the party on the ground of insanity. For a
defence resting on the ground of insanity the insanity must be clearly
proved."
In other words, the jury were told that though they believed
the defendant probably insane, she must be convicted on some pre-
sumption of law which overthrew all probabilities of fact. Is this
a sound principle of law ? Undoubtedly there are numerous authori-
ties which so declare, as there are many also going far beyond this,
and holding that the defence of insanity can never avail unless its
existence is established to the exclusion of every reasonable doubt.
There is perhaps no subject connected with criminal law upon
which the authorities are more hopelessly in conflict than the one
here presented.
Three distinct theories are held by courts and text writers of
the highest character, and each may be supported by a long array
.308 Cases on Criminal Law.
of respectable authorities, viz. : i. The prisoner must prove his
insanity beyond a reasonable doubt. 2. He must establish it by a
preponderance of evidence. 3. He must raise a reasonable doubt
as to his sanity. The first of these views receives most countenance
from English adjudications and text books ; the second is supported
by a majority of the American courts, while the third, though held
as yet perhaps by a minority of the adjudged cases, is gaining in
favor, is the well-settled law in many of the States, and is supported
by a power of reason which we deem convincing.
Every indictment charges the commission of a criminal act by
a responsible being, and no conviction can occur until the jury
shall have been satisfied beyond all reasonable doubt that such an
act has by such a being been committed. Sanity is the normal
condition of the intellect, so that when the party indicted is seen to
be a human being, the presumption of the law (because it is the pre-
sumption of common sense) is that the person is sane.
Hence, in the absence of evidence to suggest the contrary,
the jury acts on this presumption, and, the deed being proven, the
conviction follows. But if, in proving the deed, evidence is offered
which suggests a doubt of the party's sanity, the State must
promptly meet it, and this without regard to the side from which
the proof suggesting the doubt comes. The law clothes the
accused with the presumption of innocence, which he never loses
until a verdict of conviction has been pronounced. He pleads
nothing affirmatively, save in rare and exceptional instances, but by
his plea of not guilty he puts upon the State the burden of estab-
lishing every fact necessary to constitute guilt. The changing
phases of the evidence may make his case at various stages wear
various aspects. At one moment it may seem that his guilt has
been conclusively shown, and at the next it may appear to have
been as conclusively negatived ; but his own attitude never changes.
To every fresh development and every new circumstance he repeats
his plea of not guilty, and in every new complication he rests upon
his legal presumption of innocence. The testimony offered against
him may, indeed, necessitate the production of something on his
part to meet the case as made out ; but it can never do this until,
uncontradicted and unexplained, it has demonstrated his guilt
beyond a reasonable doubt. Shall it be said that, because this has
been accomplished at some particular stage of the testimony, the
.Cases on Criminal Law. 309
burden of proof has shifted, and thenceforward the duty is
imposed upon him of re-establishing his innocence beyond all
reasonable doubt ? Nobody would venture so to assert, if the
demonstration of guilt so made out was in regard to the commis-
sion of the act. Why should the rule be different in reference to
the mental accountability of the defendant ? There can be no
crime without mental accountability, and it is just as essential to
show the conscious mind as the unlawful act. But it is said that
the law presumes sanity. So the law presumes malice from the
fact of killing ; but if anything in the testimony, either of the State
or of the defendant, suggests a reasonable doubt of its existence,
nobody ever supposed that the State could stop short of removing
this doubt, and of establishing the malice to a moral certainty.
The presumptions or implications which, in criminal cases, the
law deduces from the establishment of particular facts, have no
other force than to dispense with further proof of the thing pre-
sumed, unless something in the testimony, either theretofore or
thereafter offered, suggests a doubt of the existence of the pre-
sumed fact. But the moment that doubt is engendered in refer-
ence to it, if it be as to a fact necessary to conviction, the S.tate
must establish the fact independently of the presumption ; and the
obligation to do this rests continuously upon her. The accused
need do nothing save repose upon the presumption of innocence
with which the law has clothed him, and claim the benefit of all
doubts which the testimony has evolved.
Apply those principles to sanity. Because he is a human
being, the accused is presumed to be sane. He must be sane in
order to be guilty. The trial commences with the presumption
that he is so. If nothing in the testimony suggests otherwise, there
is no obligation to establish it ; but the moment the proof warrants
a reasonable doubt of it, no matter from which side it comes, that
doubt must be removed. Which side must remove it ? Manifestly
that side which set out to show guilt, because there can be no
guilt without sanity. That condition of sanity which is ordinarily
the attribute of all men has been rendered doubtful as to this par-
ticular man, and, as his guilt depends upon his sanity, its existence
must be shown in the same manner, and to the same extent, as any
of the other elements which go to make up the crime. What logic
or consistency can there be in saying that all the other elements
310 Cases on Criminal Law.
must be established beyond a reasonable doubt, but that this one —
certainly as essential as any other — may be assumed on less satis-
factory proof? True, the case started with the theory that it
existed, but can this in anywise affect the condition in which it
must be left at the close, if it has during the progress of the trial
been rendered doubtful ? How can a jury say, We have no
doubt of the guilt of the prisoner, but we do doubt whether he was
sane ? If a jury in a capital case should bring in such a verdict,
would it not be judicial murder to inflict a sentence of death? And
yet many such verdicts are practically inevitable under a theory of
the law which holds that the burden of proving insanity rests upon
the accused, and that he must be convicted unless he has clearly
proved it beyond all probability, or beyond all reasonable doubt.
We think the true rule is this : Every man is presumed to be
sane, and in the absence of testimony engendering a reasonable
doubt of sanity, no evidence on the subject need be offered ; but
whenever the question of sanity is raised and put in issue by such
facts, proven on either side, as engender such doubt, it devolves
upon the State to remove it, and to establish the sanity of the
prisoner to thesatisfactionof the jury, beyond all reasonable doubt
arising out of all the evidence in the case. Porrard v. The State,
53 Miss., 410 ; The People v. McCann, 16 N. Y., 58 ; The State
V. Bartlett, 4.3 N. H., 224 ; The State v. Crawford, 11 Kan., 32 ;
Polk V. The State, 19 Ind., 170 ; Hopps v. The State, 31 III, 385 ;
Ogletree v. The State, 28 Ala. (N. S.), 701.
For the errors indicated in the instructions, the judgment is
reversed.^
^ Accord: St. w. Johnson, 40 Conn., 136 (1873); St. v. Reidell, 9 Houst.
(Del.), 470 (1888), [but see St. v. Cole, 2 Pennewill, 344 (1899) ] ; Hodge v.
St., 26 Fla., II (1890) ; Dacey w. P., 116 111., 555 (1886) ; Plake v. St., 121
Ind., 433 (1889); St. V. Nixon, 32 Kan., 205 (1884); P. v. Garbutt, 17
Mich., 9 (1868) ; Ballard v. St., 28 N. W. (Neb.), 271 (1886). St. v. Jones,
50 N. H., 369 (1871); Faulkner v. Territory, 6 N. Max., 464(1892); Walker
V. P., 88 N. Y., 81 (1882); Maas v. Territory, 10 Oklahoma, 714 (1901) ;
Dove 7/. St., 3 Heisk. (Tenn.), 348 (1872); Davis v. U. S., 160 U. S., 469
(1895) ; Revoir v. St., 82 Wis., 295 (1892).— Ed.
Cases on Criminal Law. 311
SECTION V.
INTOXICATION.
Lastly, although he who is drunk is for the time non compos
mentis, yet his drunkenness does not extenuate his act or offence
nor turn to his avail, but it is a great offence in itself, and, there-
fore, aggravates his offence, and doth not derogate from the act
which he did during that time, and that as well in cases touching
his life, his lands, his goods, as any other thing that concerns him.
Beverley's Case (1603) 4 Coke, p. 125.
MARSHALL'S CASE.
Lancaster Assizes, 1830.
I Lewin C. C, , 76.
On an indictment for stabbing, under the statute :
Park, J., told the jury that they might take into their consider-
ation, among other circumstances, the fact of the prisoner being
drunk at the time, in order to determine whether he acted upon a
^o«a^fl?f apprehension that his person or property was about to be
attacked.
Note. — In Goodier's case, York Summer Assizes, 1 831, Park,
J., directed the jury to the same effect.
REX V. THOMAS.
Monmouth Assizes, 1837.
7 Carrington and Payne, 817.
Indictment for maliciously stabbing. It appeared that the
prisoner and prosecutor were at a beer house together with several
other persons. Some words passed between the prisoner and a
third person, after which he was seen walking up and down the pass
age of the house with a sword stick in his hand, with the blade open,
and was heard to say : "If any man strikes me I will make
312 Cases on Criminal Law.
him repent it." He was desired to put up the stick, which
he refused to do, and shortly after, the prosecutor, ignorant of
what occurred, but perceiving the prisoner was creating a disturb-
ance, struck the prisoner twice with his fist, when the prisoner
stabbed him. Several of the witnesses were cross-examined as to
contrary statements before the magistrate.
Parke, B., in summing up the case to the jury, said :^
I must also tell you that if a man makes himself voluntarily
drunk, that it is no excuse for any crime he may commit whilst he
is so ; he must take the consequence of his own voluntary act, or
most crimes would otherwise be unpunished. But drunkenness
may be taken into consideration in cases where what the law deems
sufficient provocation has been given, because the question is, in
such cases, whether the fatal act is to- be attributed to the passion
of anger excited by the previous provocation, and that passion is
more easily excitable in a person when in a state of intoxication
than when he is sober. So, where the question is, whether words
have been uttered with a deliberate purpose, or are merely low and
idle expressions, the drunkenness of the person uttering them is
proper to be considered. But if there is really a previous determi-
nation to resent a slight affront in a barbarous manner, the state of
drunkenness in which the prisoner was ought not to be regarded,
for it would furnish no excuse. You will decide whether the sub-
sequent act does not furnish the best means of judging what the
nature of the previous expression really was.
Verdict, not guilty.
KEENAN V. COMMONWEALTH.
Supreme Court of Pennsylvania, 1862.
44 Pennsylvania, 55.
Error to the Court of Oyer and Terminer of Allegheny county.
This was an indictment against Thomas B. Keenan for the
murder of John A. Obey on the 5th day of July, 1862.^
Under the ruling of the court below [Sterrett, P. J.,] the
defendant was convicted of murder in the first degree. The case
1 Part of the opinion not relating to intoxication is omitted.
^ Part of this case is omitted.
Cases on Criminal Law. 313
was thereupon removed into this court, where the answers of the
court below to certain points which had been propounded by the
counsel for the defendant were assigned for error, all of which are
sufficiently presented in the opinion of this court.
The case was argued here by Swartzwalder and Marshall, for
the defendant, and by Miller, Hampton and Howard, for the Com-
monwealth.
The opinion of the court was delivered May 21st, 1863, by
LowRiE, C. J. Our statute adopts the common law definition
of murder, and then distinguishes it of two degrees, defining the
first degree specially by certain enumerated cases and generally by
the words " any other kind of wilful, deliberate and premeditated
killing." It is this general part of the definition that we have
to apply in the present case.
A careful study of our jurisprudence on this subject clearly
reveals the fact that such terms as a deliberate purpose or a delib-
erate and premeditated intent to kill, or a specific intent to take life,
are sometimes substituted for the words of the statute ; yet our
reported jurisprudence is very uniform in holding that the true cri-
terion of the first degree is the intent to take life. The deliberation
and premeditation required by the statute are not upon the intent,
but upon the killing. It is deliberation and premeditation enough
to form the intent to kill, and not upon the intent after it has been
formed. An intent distinctly formed, even " for a moment " before
it is carried into act, is enough.
What the definition requires, therefore, is a distinctly formed
intent to kill, not in self-defence, and without adequate provoca-
tion. It requires the malice prepense or aforethought of the com-
mon law definition of murder to be, not a general malice, but a
special malice that aims at the life of a person. This distinctly
formed intent to take life is easily distinguished, in the general, from
the instinctive and spontaneous reaction of mind and body against
insult and injury, which is often the result of no distinctly formed
intention ; and also from those cases of previous and deliberate inten-
tion to kill, which may override even what, without it, would be
adequate provocation given at the time of the killing.
Keeping this common understanding of the definition in mind,
we shall also get clear of the influence of the cases in other States,
where the terms deliberate and premeditated are applied to the
314 Cases on Criminal Law.
malice or intent, and not to the act, and thus seem to require a
purpose brooded over, formed and matured before the occasion at
which it is carried into act. Under such a definition of the inten-
tion, all our jurisprudence by which malice and intent are implied
from the character of the act, and from the deadly nature of the
weapon used, would be set aside ; for we could not, from these,,
imply such a previous and deliberate, but only a distinctly formed
intent, and this involves deliberation and premeditation, though
they may be very brief. We should therefore blot out all our law
relative to implied intent or malice, and require it to be always
proved as express. And this would be a most disastrous result,
for the most deliberate murderers are usually those who know how
to conceal their intent until the occasion arises for the execution
of it.
And still keeping in mind "our usual understanding of this gen-
eral part of the definition of murder in the first degree, we are fur-
ther prepared for an intelligent appreciation of the influence which
the fact of intoxication may legitimately have on the degree of
criminality and in the formation of the intent to kill, and in the
ascertainment of it.
The learned judge of the Oyer and Terminer charged the jury
that the prisoner's intoxication was not such an excuse as would
allow a less than ordinarily adequate provocation to palliate the
offence, unless it was so great as to render him " unable to form a
wilful, dehberate and premeditated design to kill," or, as he after-
wards expresses the thought, " of judging of his acts and their
legitimate consequences." The first of these expressions had
already been very correctly and adequately explained to the jury,
and the second one plainly means that, in using a deadly weapon
in a deadly way, the prisoner is charged with the ordinary conse-
quences of his acts, if he was not so drunk as to be unable to judge
that such would ordinarily be the consequence of such acts. The
two forms of expression are therefore the same in their meaning.
We discover no error in this instruction, and think it is in
substantial accordance with all the best considered judicial prece-
dents. And if we keep clear of the peculiarities found in other
States, arising either from misapprehension or from a differently
worded statute, we shall have little difificulty in recognizing its cor-
rectness.
Cases on Criminal Law. 3^5
No one pretends that intoxication is, of itself, an excuse or pal-
liation of a crime. If it were, all crimes would, in a great measure,
depend for their criminality on the pleasure of their perpetrators,
since they may pass into that state when they will. But it is argued
that, because intoxication produces a state of mind that is easily
excited by provocation, therefore the crimes committed under such
intoxication and provocation are less criminal than when committed
in a state of sobriety under the same provocation. We are very
sure that no statute will ever announce such a rule, and that we are
not authorized to announce it in interpreting this statute.
Stated in its most general form it amounts to this : that, because
the mind usually receives provocation with an intensity proportioned
to its own excitement or excitability, therefore the act of provoca-
tion must be measured, not by its own character and its ordinary
effect, but by the state and habit of the mind that receives it. Then,
measured by this rule, the crimes of a proud, or captious, or selfish,
or habitually ill-natured man, or one who eats or fasts too much, or
of one who is habitually quarrelsome, covetous, dishonest, or thiev-
ish, or who, by any sort of indulgence, fault, or vice, renders him-
self very easily excitable, or verj' subject to temptation, are much
less criminal than those of a moderate, well-tempered and orderly
citizen, because to the former a very small provocation or tempta-
tion becomes adequate to excuse or palliate any crime. If such
were the rule a defendant would be much more likely to injure than
to benefit his case by showing a good character, and the law would
present no inducement to men to try to rise to the standard of even
ordinary social morality.
Of course it is impossible that such a principle can be a rule
of law. If it were admitted it could not be administered, for no
judicial tribunal can have time or competence for such a thorough
investigation of the special character or state of each individual
mind as the rule requires, and therefore it would necessarily jump
to a conclusion such as the caprice or prejudice or other influence
of the moment would dictate.
The prisoner was somewhat intoxicated when, with six or seven
companions, he entered the passenger car, and he and they seem
to have behaved badly and noisily, and used very profane language
there, so that several persons preferred walking, and left the car.
Though they were twice requested by the conductor to be quiet,
3.i6 Cases on Criminal Law.
the prisoner used abusive and threatening language in reply, and
his companions and he persisted in their ill conduct, and he
expressed his determination to remain. Then the conductor took
him by the lapel of his coat and was proceeding to put him out
when he struck the conductor and was struck in return, and then
his companions joined in the scuffle and he drew a knife, and by
several strokes of it mortally wounded the conductor.
It is to such evidence as this that the judge's charge relates,
and it seems to be entirely relevant, adequate and correct, and free
from any invasion of the functions of the jury. And we say this
with special reference to those parts of the charge which say that
the prisoner ought to be taken to have intended the natural and
usual consequences of the act of using the knife in the way he did ;
that the conductor had a right to put out a passenger so misbe-
having ; that the prisoner's resistance and the blow struck by him
were his own provocation of the struggle in which he used the
knife, and neither the struggle nor the blow received in return can
be any excuse for its use. None of the other points need any
special notice. Nor do we find any error in impanneling the
jury or in the admission or rejection of evidence. We have
considered the prisoner's case with all the caution and concern
which its terrible penalties are calculated to inspire, and it is with
much sorrow, on his account, that we are compelled to say that
we discover no valid ground for granting him a new trial.
Sentence affirmed and record remitted}
FLANIGAN v. PEOPLE.
Court of Appeals of New York, i88i.
86 New York, 554.
Error to the General Term of the Superior Court of the city
of Buffalo, to review judgment entered upon an order made July 23,
1881, which affirmed a judgment of a criminal term of said court,
entered upon a verdict convicting the plaintiff in error of the crime
of murder in the first degree.
^ Accord: P. i/. Williams, 43 Cal., 344(1872); Cf. Halle v. St., 11 Humph.,
154 {1850). — Ed.
Cases on Criminal Law. 3 1 7
The plaintiff in error was indicted for the murder of one John
Karins. It appeared by the evidence that the deceased kept a
boarding-house for laborers upon a railroad, and also was foreman
or boss. The prisoner boarded with Karins, and had formerly
been at work under him, but about three months before the murder
Karins caused him to be discharged. The prisoner went to Karins'
room about 10 or 11 P. M., and stabbed him while he was asleep.
The prisoner was in the habit of drinking to excess, and was
frequently intoxicated ; he had been drinking heavily on the day
of the murder.'
Miller, J. It is claimed that the judge erred upon the trial
in refusing to charge, as requested by the prisoner's counsel, " that,
from all the evidence in the case, the jury may beheve, if they see
fit, that the prisoner may have been the victim of an appetite for
drink, entirely overcoming his will, and amounting to a disease ;
and that, if they so believe, they must acquit the prisoner, unless
they believe, beyond a reasonable doubt, that the act was not com-
mitted while his mind was overwhelmed by the effects of the liquor
so taken." The proposition contained in this request was to the
effect that the jury were authorized to believe that the prisoner was
the subject of an appetite for intoxicating drinks, which entirely
controlled his will, and to the extent of becoming a disease, and that
he was not responsible unless the crime was committed while he
was not under the influence of such disease.
The effect of this proposition would be to excuse the prisoner
from the consequences of the crime committed, if he was laboring
under intoxication so that his will was overcome, and not under his
control at the time ; in other words, that drunkenness, if carried to
the extent of producing incapacity to control the action of the
mind and will of the prisoner, would be an excuse for the crime
committed.
The rule is well settled that voluntary intoxication of one who,
without provocation, commits a homicide, although amounting to
a frenzy, does not exempt him from the same construction of his
conduct, and the same legal inferences, upon the question of intent,
as affecting the grade of his crime, which are applicable to a person
entirely sober. People v. Rogers, 18 N. Y., 9.
1 Part of this case is omitted
3i8 Cases on Criminal Law.
Within the rule laid down in the case cited, we think that the
request to charge cannot be sustained. The position of the learned
counsel for the prisoner is, that he had a right to go to the jury
upon the question whether intoxication was a disease, as described
in the request, and whether the prisoner was afflicted with it, and,
if the jury found both of these facts, the drunkenness could not
have been voluntary, and, if the jury believed the mind was over-
whelmed by means thereof, that the prisoner must be excused as an
insane man. It may be answered that no such distinct request was
made ; but, aside from this, the position taken would be adverse to
the principle which has been established by a long series of deci-
sions, and, if enforced, might lead to exonerate offenders for crimes
committed by them when under the influence of intoxicating drinks,
and thus furnish an excuse for the commission of the most heinous
offences. The authorities all agree upon the proposition that mental
alienation, produced by drinking intoxicating liquors, furnishes no
immunity for crime, and, to sustain the doctrine asserted, it would
be necessary to overrule this well-established principle. The propo-
sition contained in the request was also objectionable, as it assumed
that, if the prisoner had become the victim of an appetite for strong
drinks so as to overcome his will, and amounting to a disease, even
although he was able to distinguish between right and wrong at
the time of, and with respect to, the act committed, he should be
acquitted. Flanagan v. The People, 52 N. Y., 467.
The finding of the jury that the prisoner was affected with the
alleged disease would not exonerate htm from responsibility for the
crime, and his intoxication did not authorize the court to charge as
requested.
No error was, therefore, committed in the refusal of the judge to
grant the request, nor was there any error in the refusal of the judge
to charge, as requested, that the jury might " take into consider-
ation the fact of drunkenness, as affecting each of the questions of
deliberation and premeditation."
The question presented by this request has been the subject
of consideration in the reported decisions in the courts of this
State. In The People v. Rogers {supra), a request was made by
the prisoner's counsel to charge the jury to the effect that drunk-
enness might exist to such a degree that neither an intention to
murder, nor a motive for the act, could be imputed to the prisoner.
Cases on Criminal Law. 3^9
The request was refused, and Denio, J., in discussing the question,
says : " This would be precisely the same thing as advising them
that they might acquit of murder on account of the prisoner's
intoxication if they thought it sufficient in degree. It has been
shown that this would be opposed to a well-established principle of
law." He further remarks : " The judge ought to have charged
that if a man makes himself voluntarily drunk, that is no excuse for
any crime he may commit while he is so, and that he must take the
consequences of his own voluntary act." The doctrine thus laid
down in principle would sustain the refusal of the judge to charge
as requested in the case at bar. In Kenny v. The People, 31
N. Y., 330, the prisoner was convicted of murder in the first
degree, committed while in a state of voluntary intoxication, upon
a sudden impulse. The court instructed the jury that voluntary
intoxication can furnish no excuse or immunity for crime, and so
long as the offender is capable of conceiving a design, he will be
presumed, in the absence of contrary proof, to have intended the
natural consequences of his own acts. The judge was requested
to charge, among other things, that intoxication may be considered
in determining whether the homicide was committed by a premedi-
tated design, which was refused, and it was held by this court that
there was no error in declining to charge as requested, and Potter,
J., cites from the People v. Rogers the remarks we have already
quoted from the opinion in that case, and says that " The People v.
Rogers, and the opinions delivered therein and the authorities
cited, are conclusive, and control this case." He further remarks
that " the rule established in that case, and in fact, the uniform rule
in all the cases is, that where the act of killing is unequivocal and
unprovoked, the fact that it was committed while the perpetrator
was intoxicated cannot be allowed to affect the legal character of
the crime." This case is directly in point in regard to the subject
of premeditation, and the principle laid down would seem to cover
deliberation also. As, however, the judge subsequently, in response
to a request made by the prisoner's counsel to the effect that the
jury might take into consideration the question of drunkenness as
affecting the fact of deliberation, said that he had so charged and
had left it to the jury to determine as to the degree of murder and
whether there was deliberation, and thus allowed the jury to con-
sider the intoxication of the prisoner in reference to deliberation, it
320 Cases on Criminal Law.
is not necessary to determine the question whether the refusal to
charge as to deliberation was erroneous.
The judge also charged, in response to a request of the
prisoner's counsel, that if the jury believed that the prisoner
was under the influence of liquor or drink at the time of the com-
mission of the act, they might take into consideration the drunken-
ness of the prisoner, as to whether it did not render more weighty
the presumption of his having yielded to sudden passion rather
than to previous malice. In an earlier portion of his charge, he
stated that premeditation and deliberation was essential to estab-
lish murder in the first degree, and the entire charge on the ques-
tion discussed was quite as favorable to the prisoner as the evidence
warranted. The evidence was quite clear as to the intention of the
prisoner, and to sanction a rule that his drunkenness was an excuse
would be adverse to the whole current of authority and what has
been understood to be well-established law.
The judgment should, therefore, be affirmed, and the record
remitted to the court below with directions to proceed as required
by law.
All concur. Andrews, J., entertained some doubt upon the
point whether the court did not err in refusing to charge that the
jury might consider the fact of drunkenness upon the point of pre-
meditation as well as upon the point of deliberation.
Judgment affirmed.
STATE V. HAAB.
Supreme Court of Louisiana, 1901.
105 Louisiana, 230.
NiCHOLLS, C. J. In this case, defendant, Fred. H. Haab,
indicted for murder, convicted of manslaughter and sentenced to
imprisonment for six years, at hard labor, in the penitentiary, has
appealed from the sentence rendered, upon a number of grounds
embodied in bills of exception and assignment of error, which we
have examined with great care.^
' Part of the opinion is omitted.
Cases on Criminal Law. 321
We think that the evidenqe disclosed that, for some time pre-
vious to the homicide, at the time of the homicide, and up to the
time of his arrest, the accused had been continually drinking
heavily and getting drunk ; that he was drunk at the time of the
homicide. It is claimed for the defense that during this whole
period the condition of his mind was such as to render him unable
to distinguish right from wrong, and that his long continuance in
excessive drinking had brought him into such a condition that he
was unable to resist drinking and getting drunk ; that his condition
of mind was such as to give rise to delusions on his part that he
was about to be attacked and killed.
It is claimed that during this long debauch he had delirium
tremens also at some time prior to the homicide ; it is claimed that
there was evidence to show that he was in fact crazy or insane at the
time of the homicide, and that though this was the result of heavy
drinking the accused was, nevertheless, excusable for the homicide.
Referring to one of the special charges requested by the
accused, wherein reference is made to a person being first crazy
and then getting drunk, and while " crazy drunk " committing
homicide, the court said : " No evidence supports this charge.
The accused was never deranged before this particular spree, nor
after. It was one continuous debauch beginning, according to his
witnessess, about six weeks before the homicide, while the alleged
insanity appeared about two weeks before the homicide. After the
killing the accused recovered in a few days. Drunkenness pre-
existed the alleged insanity." The judge further said that he had,
in his general charge, announced the principles of law declared in
that charge, though he did not think it applied to the defendant's
case. He did charge that "if the intoxication was the result of
pre-existing insanity and the accused, by reason of such pre-existing
insanity could not overcome his desire to gratify his thirst for drink,
then such insanity would be the actuating cause of the crime, and
the jury should so consider it. If, however, his excessive indulgence
in liquor was caused by his own negligence and he had an oppor-
tunity of correcting his weakness, and failed to do so, he is respon-
sible for the results of his own excesses, accordingly, as you have
been instructed in this charge, that is, if a temporary result, he
would be responsible ; if a permanent result he would be irre-
sponsible."
322- Cases on Criminal Law.
The district judge, at the foot of the bill of exceptions taken
by the accused to his refusal to give to the jury the special charge
that " the law recognizes the existence of a form of diseased mind
known as delirium tremens, induced by the excessive use of stimu-
lating drink, and in the event of a homicide committed by one
laboring under such disease to a degree that dethrones reason and
prevents him from knowing the difference between right and wrong,
such homicide would be excusable, although such mental disease
was not permanent and was due to the excessive drinking of
alcoholic stimulants," made the following statement, evidently
intended for the Supreme Court's consideration and not that of the
jury :
" If Haab's condition at the time he fired the fatal shot could
be properly designated as delirium tremens (which I deny), it must
be shown to be — (i) a fixed, settled or permanent condition and not
a temporary one, as in this case. If a man voluntarily drinks to
excess, temporarily destroying his mental soundness to such an
extent as not to know the difference between right and wrong, and
while in this condition commits an unlawful homicide, his act is
inexcusable, whether you designate his mental condition as simple
drunk, drunk to stupefaction, crazy drunk or insane, dementia or
delirium tremens. The temporary character of his affection makes
him responsible. A state of disease brought about by a person's
own act, as delirium tremens caused by excessive drinking, is no
excuse for committing a crime, unless the disease so produced is
permanent. Withaus & Beeker, vol. 3, page 491 ; i Hale P. C. 32;
4 Black, 26 ; State v. Kramer, 49 Ann. 774. This is the common
law.
" (2) It must also be shown that the delirium tremens was not
the immediate product of excessive drinking, but a remote con-
sequence of it. The facts are that Haab's mental condition may
have been unsound at the time of the homicide, but was the
immediate result of his undue indulgence in spirituous liquors and
not the result of any previous sprees or drunkenness; that after
the killing he was jailed and recovered in five or six days permanently.
Under this state of facts the court declined to make any distinctions
with reference to his unsound condition of mind. If he was merely
' crazy drunk,' as it is vulgarly called, he would be just as much
entitled to an acquittal if he could not tell the difference between
Cases on Criminal Law. 323
right and wrong as he would be if his condition was designated as
a delirium.
"Criminal indulgence in the use of spirituous liquors would be
the basis of both conditions."
Under other bills the court said :
" There was no evidence to show that delusion in this case
was occasioned by a 'fixed' frenzy. There was nothing 'fixed' in
defendant's mental condition. The evidence shows that his alleged
mental derangement as a fact was temporary, and was created by the
excessive use of spirituous liquors. The delusions, if any, were
incidents to the excessive drinking. As to the statement that this
accused was both drunk and insane : This phraseology may be
misleading. It may imply there was evidence to show that the
alleged insanity and drunkenness were two separate and distinct
conditions proceeding from different causes. There was no evidence
in support of such a fact. The evidence showed that Haab's
symptoms, whatever they were, proceeded from one and the same
cause and were its immediate and connecting effects, differing only
in degree. Naturally, the continued use of spirituous liquors on
one debauch without interruption, as in this case, would intensify
each succeeding effect. A man who becomes ' crazy drunk ' reaches
this condition by stages."
Referring to one of the charges requested, but refused, the
court said :
" It failed to distinguish between a mental unsoundness, the
immediate result of excessive drink, and one by long continued
habit, a remote consequence of it. If one should become voluntarily
drunk in the morning, indulging to such excess during the day as
to lose all power of controlling the desire for drink and continuing
his excesses at night, until drunk to madness, and in this condition
should unlawfully slay another, such killing under the charge re-
quested would be excusable."
In his reasons for refusing a new trial the judge said :
" The accused began drinking immoderately and was under
the influence of liquor to a greater or less degree continually and
without intermission for two weeks before the homicide, until its
effects wore off, after his arrest and incarceration, when he
ceased drinking. It makes no difference by what terms you desig-
nate the temporary effects of his excesses, whether called an ordinary
324 Cases on Criminal Law.
drunk, drunk to stupefaction, delirium tremens, drunk to frenzy,
insanity, etc., if it were the immediate product of this particular
debauch he is responsible for his acts under its influence. There was
no evidence whatever that Haab's condition was a remote con-
sequence of long continued prior excesses, nor that he had ever
been in this condition before. In the opinion of the court, at the
time of the firing of the fatal shot Haab was not suffering from
delirium tremens ; he was merely afflicted with that nervousness that
always accompanies immoderate indulgence in hquor."
We have referred to United States v. Drew, cited by counsel,
and reported in 5 Mason's Reports, page 29, C. C. R. The accused
upon an admitted state of facts was declared insane and discharged.
In the course of his opinion in the case, Judge Story used the
following language :
" In general, insanity is an excuse for the commission of every
crime, because the party has not the possession of that reason which
includes responsibility. An exception is when the crime is com-
mitted by a party while in a state of intoxication, the law not per-
mitting a man to avail himself of his own gross vice and misconduct
to shelter himself from the legal consequences of such crime. But
the crime must take and be the immediate result of a fit of intoxi-
cation and while it lasts and not as in this case a remote consequence
superinduced by the antecedent exhaustion of the party arising from
gross and habitual drunkenness. However criminal, in a moral
point of view, such an indulgence is, and however justly a party
may be responsible for his acts arising from it to Almighty God,
human tribunals are generally restricted from punishing them, since
they are not the acts of a reasonable being. Had the crime been
committed while defendant was in a fit of intoxication he would have
been liable to be convicted of murder. As he was not then intoxi-
cated, but merely insane from an abstinence from liquor he cannot
be pronounced guilty of the offense. The law looks to the imme-
diate and not to the remote cause — to the actual state of the party
and not to the causes which remotely caused it.
" Many species of insanity arise remotely from what, in a moral
view, is a criminal negligence or fault of the party, as from religious
melancholy, undue exposure, extravagant pride, ambition, etc. Yet
such immunity has always been deemed a sufficient excuse for any
crime done under its influence."
Cases on Criminal Law. 325
We think it fairly appears from the recitals of the accused and
those of the judge that the accused was in a state of intoxication at
the time of the homicide, and that his mental condition at that time,
whatever it might be, was the immediate and direct result and not
the remote result of voluntary drunkenness. When we say direct
and immediate result, we mean to say that it arose during a con-
dition of drunkenness and pending a single, continuing, voluntary
drunken debauch which, at its origin, started with the accused in a
condition of sanity. The results were in a legal sense immediate
and direct results, though the beginning of the drunken debauch
may have dated some days back, or even some weeks before the
homicide.
We think under the recitals in the case, that it is precisely
such a. one as Mr. Justice Story refers to in which he says, " insanity
or a condition of mind substantially that of insanity, would not
serve as a shelter or a protection against crime."
We think that this was the view taken by the district judge of
the facts and law of the case, a view which he endeavored to place
before the jury in his charge. We think he fairly advised the jury
as to the law, though there were some expressions in his charge
which he might well have omitted, as they doubtless did not instruct
and may perhaps have to some extent confused the jury. We do
not think, however, they were led into error or misled by these
expressions, or that they were prejudicial. It is well for a judge
charging a jury as to insanity to avoid as far as possible the use of
technical medical terms as to the various forms and shades of
mental disease.
They are not likely to enlighten or impress the jury and are
very liable to technical objections.
We do not think there is any ground for the reversal of the
judgment, and it is hereby affirmed.
Rehearing refused.
326 -Cases on Criminal Law.
WRITTEN V. STATE.
Supreme Court of Alabama, 1896.
115 Alabama, 72.
Coleman, J. The defendant was indicted and convicted
for an assault with intent forcibly to ravish. There was evidence
introduced on the trial, to show that at the time of the misconduct
of the defendant, he was sober, and there was evidence tending to
show that he was drunk. On this phase of the evidence, the
defendant requested the court to give the following charge : " The
presumption in this case is that the defendant is innocent until the
State has proven beyond all reasonable doubt that he is guilty ;
and if the jury have a reasonable doubt growing out of i.\\ the
evidence, as to whether he was sufficiently sober to form the
specific intent to ravish, then the jury cannot find the defendant
guilty of an assault with intent to ravish." This charge was refused.
We are of opinion the charge should have been given. In order
to convict under the statute for an assault with intent to ravish, it
is necessary to satisfy the jury beyond a reasonable doubt, that the
defendant entertained the specific intent charged and made the
assault, to accomplish the specific purpose. Mere drunkenness
does not excuse or palliate an offense, but it may produce a state
of mind, which incapacitates the party from forming or entertaining
a specific intent. If the mental condition is such that a specific
intent cannot be formed, whether this condition is caused by
drunkenness or otherwise, a party cannot be said to have committed
an offense, a necessary element of which is, that it be done with a
specific intent*
The rule at one time prevailed that the burden was on the
defendant to show to the satisfaction of the jury, that he was
incapable of forming the specific intent. Fonville's Case, 91 Ala. 39,
and authorities cited. We think the better and latest rule is, that
1 Accord: assaultwith intent to murder, Crosby v. P. 137 111. 325 (1891) ;
attempt, Reagan v. St. 28 Tex. App. 227 (1889) ; bribery. White v. St. 103
Ala. 72 (1893); burglary, St. v. Bell, 29 Iowa, 316 (1870); Schwabacher v. P.
165 111. 618 (1897) ; conspiracy, Booker v. St. 156 Ind. 435 (1901) ; forgery,
P. V. Blake, 65 Cal. 275 (1884) ; larceny, Wood v. St. 34 Ark. 341 (1879) '>
Chatham v. St. 92 Ala. 47 (1890). — Ed.
Cases on Criminal Law. 327
if upon consideration of all the evidence, the jury have a reason-
able doubt of the defendant's guilt, he is entitled to an acquittal ;
and the application of this principle is not affected by reason of the
fact that the criminating testimony offered by the prosecution, may
have imposed upon the defendant the burden to overcome its
effect. If the offense is of such a character, that the exercise of a
specific intent is a necessary element in its commission, it cannot
be said, that a jury should be satisfied beyond a reasonable doubt
of the defendant's guilt so long as the jury have a reasonable doubt
arising from the evidence, that the defendant was capable of form-
ing such specific intent Any other rule would authorize a verdict
of guilty in a criminal case on a less degree of proof and conviction
of the judgment than that of satisfaction beyond a reasonable doubt.
Henson v. The State, 112 Ala. 41 ; Chatham v. The State, 92
Ala. 47 ; King v. The State, 90 Ala. 612 ; Walker v. The State,
91 Ala. 76.^
The condition of the defendant's mind, arising from his vol-
untary drunkenness, was no excuse for the assault, an offense
included in that charged. It can only be considered upon the ques-
tion of his guilt of the statutory offense for which he was indicted,
to wit, an assault with intent to forcibly ravish, which involves the
condition of the defendant's mind. Engelhardt v. The State, 88
Ala. 100.
Reversed and remanded,
1 Accord : Davis v. St. 54 Neb. 177(1898). Contra: C. v. Haggerty,
(Pa.) Lewis, U. S. Cr. L. 402 (1847) ; St. v. Grear, 29 Minn. 221 (1882) ; St
V. Hill, 46 La. Ann. 27 (1894). — Ed.
328 Cases on Criminal Law.
SECTION VI.
INCORPORATION.
ANONYMOUS.
King's Bench, 1702.
12 Modern, 559.
Note. — Per Holt, Chief Justice. A corporation is not in
dictable but the particular members of it are.
UNITED STATES v. JOHN KELSO COMPANY.
United States District Court for California, 1898.
86 Federal Reporter, 304.
De Haven, District Judge. On October 9, 1897, there was
filed in this court by the United States district attorney for this dis-
trict, an information charging the defendant, a corporation, with
the violation of "An act relating to the limitation of the hours of
daily service of laborers and mechanics employed upon the public
works of the United States and of the District of Columbia,"
approved August i, 1892, 2 Supp. Rev. St. p. 62. Upon the
filing of this information, the court, upon motion of the district
attorney, directed that a summons in the general form prescribed
by section 1390 of the Penal Code of this state, be served upon
said corporation, and accordingly on said date a summons was
issued, directing the defendant to appear before the judge of said
court in the court room of the United States district court for this
district on the 21st day of October, 1897, to answer the charge
contained in the information. The summons stated generally the
nature of the charge, and for a more complete statement of such
offense referred to the information on file. On the day named in
Cases on Criminal Law. 329
said summons for its appearance, the defendant corporation ap-
peared specially by its attorney, and moved to quash the summons,
and to set aside the service thereof, upon grounds hereinafter
stated. Upon the argument of this motion, it was claimed in be-
half of the defendant : First, that the act of congress above
referred to does not apply to corporations, because the intention is
a necessary element of the crime therein defined, and a corpora-
tion as such is incapable of entertaining a criminal intention; second,
that, conceding that a corporation may be guilty of a violation of
said act, congress has provided no mode for obtaining juris-
diction of a corporation in a criminal proceeding, and for
that reason the summons issued by the court was unauthorized by
law, and its service a nullity. It will be seen that the first objec-
tion goes directly to the sufficiency of the information, and pre-
sents precisely the same question as would a general demurrer,
attacking the information on the ground of an alleged failure to
charge the defendant with the commission of a public offense.
This objection is one which would not ordinarily be considered
upon a motion like that now before the court, when the party
making the objection refuses to acknowledge the jurisdiction of the
court, or to make any other than a special appearance for the pur-
pose of attacking its jurisdiction ; but, in view of the conclusion
which I have reached upon the second point urged by the defend-
ant, it becomes necessary for me to determine whether the act of
congress above referred to is applicable to a corporation, and
whether a corporation can be guilty of the crime of violating the
provisions of said act. Section i of that act makes it unlawful for
a contractor or subcontractor upon any of the public works of the
United States, whose duty it shall be to employ, direct, or control
the services of laborers or mechanics upon such public works, "to
require or permit any such laborer or mechanic to work more than
eight hours in any calendar day except in case of extraordinary
emergency." And section 2 of the act provides "that * * *
any contractor whose duty it shall be to employ, direct, or control
any laborer or mechanic employed upon any public works of the
United States * * * who shall intentionally violate any pro-
vision of this act, shall be deemed guilty of a misdemeanor, and
for each and every offense shall upon conviction be punished by a
fine not to exceed one thousand dollars or by imprisonment for
330 Cases on Criminal Law.
not more than six months, or by both such fine and imprisonment,
in the discretion of the court having jurisdiction thereof." It will
be observed that by the express language of this statute there must
be an intentional violation of its provisions, in order to constitute
the offense which the statute defines. In view of this express
declaration, it is claimed in behalf of defendant that the act is not
applicable to corporations, because it is not possible for a corpora-
tion to commit the crime described in the statute. The argument
advanced to sustain this position is, in substance, this: That a cor-
poration is only an artificial creation, without animate body or
mind, and therefore, from its very nature, incapable of entertaining
the specific intention which, by the statute, is made an essential
element of the crime therein defined. The case of State v. Great
Works M. & M. Co., 20 Me. 41, supports the proposition that a
corporation is not amenable to prosecution for a positive act of
misfeasance, involving a specific intention to do an unlawful act,
and it must be conceded there are to be found dicta in many other
cases to the same effect. In a general sense, it may be said that
no crime can be committed without a joint operation of act and
intention. In many crimes, however, the only intention required
is an intention to do the prohibited act, — that is to say, the crime
is complete when the prohibited act has been intentionally done ;
and the more recent and better considered cases hold that a cor-
poration may be charged with an offense which only involves this
kind of intention, and may be properly convicted when, in its cor-
porate capacity, and by direction of those controUing its corporate
action, it does the prohibited act. In such a case the intention of
its directors that the prohibited act should be done is imputed to
the corporation itself. State v. Morris E. R. Co., 23 N. J. Law,
360 ; Reg. V. Great North of England Ry. Co., 58 E. C. L. 315 ;
Com. z/. Proprietors of New Bedford Bridge, 2 Gray, 339. See,
also, State z/. Baltimore & O. R. Co., 15 W. Va. 380. That a
corporation may be liable civilly for that class of torts in which a
specific malicious intention is an essential element is not disputed
at this day. Thus an action for malicious prosecution will lie
against a banking corporation. Reed v. Bank, 130 Mass. 434;
Goodspeed v. Bank, 22 Conn. 530. An action will lie also against
a corporation for a malicious libel. Railroad Co. v. Quigley, 21
How. 202; Maynard T^. Insurance Co., 34 Cal. 48. The opinion
Cases on Criminal Law. 331
in the latter case, delivered by Currey, C. J., is an able exposition
of the law relating to the liability of corporations for malicious
libel, and in the course of which that learned judge, in answer to
the contention that corporations are mere legal entities existing
only in abstract contemplation, utterly incapable of malevolence,
and without power to will good or evil, said :
"The directors are the chosen representatives of the corpora-
tion, and constitute, as already observed, to all purposes of dealing
with others, the corporation. What they do within the scope of
the objects and purposes of the corporation, the corporation does.
If they do any injury to another, even though it necessarily in-
volves in its commission a malicious intent, the corporation must
be deemed by imputation to be guilty of the wrong, and answer-
able for it, as an individual would be in such case."
The rules of evidence in relation to the manner of proving the
fact of intention are necessarily the same in a criminal as in a civil
case, and the same evidence which in a civil case would be suf-
ficient to prove a specific or malicious intention upon the part of a
corporation defendant would be sufficient to show a like intention
upon the part of a corporation charged criminally with the doing of
an act prohibited by the law. Of course, there are certain crimes
of which a corporation cannot be guilty ; as, for instance, bigamy,
perjury, rape, murder, and other offenses, which will readily sug-
gest themselves to the mind. Crimes like these just mentioned
can only be committed by natural persons, and statutes in relation
thereto are for this reason never construed as referring to corpora-
tions ; but when a statute in general terms prohibits the doing of
an act which can be performed by a corporation, and does not ex-
pressly exempt corporations from its provisions, there is no reason
why such statute should be construed as not applying to them,
when the punishment provided for its infraction is one that can be,
inflicted upon a corporation, — as, for instance, a fine. In the act
of congress now under consideration it is made an offense for any
contractor or subcontractor whose duty it shall be to employ,
direct or control any laborer employed upon any of the public
works of the United States, to require or permit such laborer to
work more than eight hours in any calendar day. A corporation
may be a contractor or subcontractor in carrying on public
works of the United States, and as such it has the power or capacity
332 Cases on Criminal Law.
to violate the provision of this law. Corporations are, therefore,
within the letter, and, as it is as much against the policy of the law
for a corporation to violate these provisions as for a natural person
so to do, they are also within the spirit of this statute ; and no
reason is perceived why a corporation which does the prohibited
act should be exempt from the punishment prescribed therefor.
If the law should receive the construction contended for by the
defendant, the result would be that a corporation, in contracting
for the doing of any public work, would be given a privilege
denied to a natural person. Such an intention should not be im-
puted to congress, unless its language will admit of no other inter-
pretation.^
The motion of the defendant will be denied.^
^ Part of the opinion involving another point is omitted.
* Accord : Nuisance, North. Cent. Ry. Co. v. C, 90 Pa., 300 (1879);
contempt of court, Telegram Newspaper Co. v. C, 172 Mass., 294 (1899).
Contra: as to misfeasance, St. v. Ohio & Miss. R., 23 Ind., 362 (1864). — Ed.
Cases on Criminal Law. 333
Chapter VI.
The Criminal Act.
SECTION I.
CONCURRENCE OF ACT AND INTENT.
REGINA V. MATTHEWS.
Court of Criminal Appeal, 1873.
12 Cox C. C, 489.
BoviLL, C. J.^ We have considered this case, and have come
to the conclusion that the conviction must be quashed. The jury
have found that at the time the prisoner found the heifers he had
reasonable expectation that the owner could be found, and that
he did not believe that they had been abandoned by the owner.
But at the same time they have found that at the time of finding
the heifers the prisoner did not intend to steal them, but that the
intention to steal came on him subsequently to the first interview
with Stiles. That being so, the case is undistinguishable from Reg.
V. Thurborn, 3 Cox C. C. 453, and the cases which have followed
that decision. Not having any intention to steal when he first found
them, the presumption is that he took them for safe custody, and
unless there was something equivalent to a bailment afterwards, he
could not be convicted of larceny. On the whole we think there
was not sufficient to make this out to be a case of larceny by a
bailee.
Conviction quashed.
1 The opinion only is printed.
334 Cases on Criminal Law.
MILTON V. STATE
Supreme Court of Florida, 1898.
40 Florida, 251.
Mabry, J.^ The following instruction given by the court to
the jury was excepted to by defendant, viz: "If you believe
from all the testimony in this case that the defendant was informed
that, in a certain house, an offense was being committed against the
ordinances of the city of Tampa, and that the defendant was a
policeman of the city of Tampa at the time, then it was his duty,
and it was lawful, if not resisted, for him to go into said house for
the purpose of preventing, or arresting those who might in his
presence be guilty of a violation of the ordinances of said city ;
but if you believe from all the evidence in this case that he went to
that house in "good faith as an officer of the law to enforce the
law, and after he got in there,. violated the law himself, then the
law removes its sanction to such entry, and he becomes a tres-
passer from the beginning." This charge is not correct, and we
find no authority to sustain it. The Circuit Judge must have failed
to observe the distinction obtaining in the civil and criminal depart-
ments of the law in the application of the rule sought to be invoked
in the charge. Mr. Bishop says, vol. i Crim. Law, § 208, 8th
edition, "in civil jurisprudence we have the rule that when a man
does a thing by permission of law — not by license, but by permis-
sion of law — and, after proceeding lawfully part way, abuses the lib-
erty the law had given him, he shall be deemed a trespasser from the
beginning by reason of this subsequent abuse. But this doctrine
does not prevail in our criminal jurisprudence ; for no man is
punishable criminally for what was not criminal when done, even
though he afterwards adds either the act or the intent, yet not the
two together." The cases cited, State v. Moore, 12 N. H. 42 and
Commonwealth v. Tobin, 108 Mass. 426, S. C. 11 Am. Rep. 375,
sustain the text.
The judgment is reversed and a new trial atvarded.
1 Part of the opinion is omitted.
Cases on Criminal Law. 33 S
REGINA V. SUTTON.
Court for Crown Cases Reserved, 1838.
2 Moody, 29.
The prisoner was tried before Mr. Baron Alderson at the
Spring assizes for the county of Gloucester, 1838, upon an indict-
ment which contained two counts : — first, for steaHng a sheep ;
secondly, for killing the same with intent to steal the carcase.
The jury found the prisoner guilty upon the latter count
only.
It appeared that the prisoner was interrupted by the prose-
cutor, who came into his field whilst the prisoner was in the act of
killing the sheep. The sheep, however, had only been wounded
in the throat, the jugular vein being cut on one side of it, but not
altogether through. The animal was immediately removed by the
prosecutor to his own house, and the wound sewed up, but it died
in two days.
The jury found the prisoner had given to the sheep a deadly
wound, of which it died two days after, with intent to steal the
carcase.
Upon these facts the learned Baron directed them to find a
verdict of guilty upon- the second count. See Clay's case,
R. & R. 387.
In Easter term, 1838, Lord Denman, C. J., Tindal, C. J.,
Lord Abinger, C. B., Park, J., Litiledale, J., Parke, B.,
BOLLAND, B., BOSANQUET, J., AlDERSON, B., PaTTESON, J., COLE-
ridge, J., CoLTMAN, J., Considered this case, and unanimously held
the conviction right.
PINKARD V. STATE.
Supreme Court of Georgia, i860.
30 Georgia, 757.
The plaintiff in error was indicted and found guilty of simple
larceny. He moved for a new trial on the following grounds : 4th.*
Because the court erred in refusing to charge the jury as requested
by the counsel for defendant, in writing, that, if they, the jury,
J- Part of this case is omitted.
336 Cases on Criminal Law.
believe from the evidence that Pinkard, the defendant, did agree
with Perry and Axon to steal the negro woman belonging to
Brinsfield, yet if they believe that Pinkard abandoned the purpose,
and went off and did not participate in the crime, then the jury
must find the defendant not guilty.
By the Court. Lumpkin, J., delivering the opinion.
We think the fourth charge should have been given. The law
as well as the gospel allows a place of repentance, and, notwith-
standing the accused may at one time have agreed to engage in
this crime, yet, if he afterwards changed his mind and abandoned
that intention, he is not guilty. And there was proof in that case
to warrant a charge to that effect.
SECTION II.
SUFFICIENCY OF THE ACT.
(a) Solicitation.
BACON'S CASE.
King's Bench, 1664.
Levinz, 146.
He was indicted for intending to murder the Master of the
Rolls, and for offering 100/. to J. S. to do it ; and saying. That, if
he would not, he would do it himself; and he being convicted, it
was moved that this intent only was not indictable : But the Court
to the contrary said: "Anciently the will was reputed or taken for
the deed in matters of felony, and tho' it is not so now, yet it is an
offense and finable ; and they fined him 1000 marks, three months'
imprisonment, and to find sureties of good behavior during life."^
1 In some Year Books of the fourteenth century we find our lawyers ap-
pealing to a * * * dangerous maxim, voluntas reputabitur pro facto.
See Coke, Third Instit. 5 ; Stephen, Hist. Crim. Law, ii., 222. This was, we
believe, due to the fact that, owing to the disuse of appeals, our criminal law
had become far too lenient in cases of murderous assaults which did not cause
death. We * * * believe that the adoption, even for one limited pur-
pose, of this perilous saying was but a momentary aberration. Our old law
started from the other extreme : factum reputabitur pro voluntate. Pollock
& Maitland's Hist. Eng. Law, Vol. II, p. 475, n. — Ed.
Cases on Criminal Law. 337
REX V. HIGGINS.
King's Bench, i8oi.
2 East, 5.
The defendant was indicted for a misdemeanor at the quarter
sessions for the county of Lancaster, and was convicted on the
second count of the indictment, charging, " That he on, &c., at, &c.,
did falsely, wickedly, and unlawfully solicit and incite one James
Dixon, a servant of J. Phillips, &c., to take, embezzle, and steal a
quantity of twist, of the value of three shillings, of the goods and
chattels of his masters J. P., &c., aforesaid, to the great damage ot
the said J. P., &c., to the evil example, &c., and against the peace,"
&c. After judgment of the pillory and two years' imprisonment, a
writ of error was brought, and the following causes assigned for
error: i. That the said count does not set forth any misdemeanor
or offense which the justices of peace at their quarter sessions had
jurisdiction to determine.'
The case was twice argued ; first in Trinity term last by
Scarlett for the defendant and Cross for the crown ; and now Top-
ping for the defendant, and Christian for the crown.
Le Blanc, J. It is contended, that the offense charged in the
second count, of which the defendant has been convicted, is no
misdemeanor because it amounts only to a bare wish or desire of
the mind to do an illegal act. If that were so, I agree that it
would not be indictable. But this is a charge of an act done ;
namely, an actual solicitation of a servant to rob his master, and
not merely a wish or desire that he should do so. A solicitation
or inciting of another, by whatever means it is attempted, is an act
done ; and that such an act done with a criminal intent is punishable
by indictment has been clearly established by the several cases
referred to. The cases of R. v. Daniel, and R. v. Callingwood,
cited for the defendant, do not support the proposition that a mere
solicitation is not indictable : on the contrary Lord Holt says in the
former case, 6 Mod. 10 1, that perhaps an indictment might be
for the evil act of persuading another to steal. That part of
the case, however, was determined upon the want of a venue.
1 Part of this case is omitted.
338 Cases on Criminal Law.
And in R. v. Callingwood, 2 Ld. Raym., Iii6, the only
point determined was, that the first part of the charge
which was for enticing an apprentice to take and carry away
goods from his master, was not indictable, being only a private
injury for which an action on the case would lie, but not of
such a public nature as to maintain an indictment ; and that the
second part of the charge was not well laid for want of a venue.
Judgment affirmed}
COMMONWEALTH v. HUTCHINSON.]
Superior Court of Pennsylvania, 1898.
6 Pennsylvania Superior Court, 405.
Opinion by Smith, J., January 18, 1898 :
The defendant was convicted and sentenced on the charge of
soliciting one Robert Williams to burn a store building.^
It is contended, on the part of the defense, that solicitation to
commit a misdemeanor is not indictable, and that, as the indict-
ment charges only such solicitation, it sets forth no criminal
offense.
There seems no question that solicitation to commit a felony
is a misdemeanor : Rex v. Higgins, 2 East, 5 ; Rex v. Hickman,
I Moody, 34; Reg. v. Quail, 4 F. & F. 1076 ; State v. Avery, 7
Conn. 266 ; People v. Bush, 4 Hill, 133 ; Com. v. McGill, et al.^
Add. 21 ; State v. Bowers, 15 L. R. A. 199. This, however, can
not be affirmed of the broad proposition that solicitation to commit
a misdemeanor is itself a misdemeanor. On the contrary, it seems
clear that with respect to various misdemeanors, involving little or
no moral turpitude or prejudice to society, solicitation to their
commission is not in law an offense. It is equally clear that as to
certain others, it is an offense. The cases cited in Wharton's
Criminal Law, sec. 179, show that such solicitations are indict-
^ Kenyon, C. J., and Grose and Lawrence, JJ., delivered concurring
opinions.
^ The indictment and part of the opinion relating to a question of evi-
dence are omitted.
Cases on Criminal Law. 339
able, "when their object is interference with public justice, as when
a resistance to the execution of a judicial writ is counseled, or
perjury is advised, or the escape of a prisoner is encouraged, or the
corruption of a public officer is sought, or is invited by the officer
himself." In Rex v. Phillips, 6 East, 464, it was held that solicita-
tion to commit a misdemeanor of an evil and vicious nature was
indictable. The authorities collected in the notes to Washington
V. Butler, 25 L. R. A. 434, embrace cases in which it was held
indictable to solicit another to make a plate for counterfeiting bills
of exchange ; to commit assault and battery ; to commit perjury.
There is also a class of cases frequently referred to in the discus-
sion of this question, but really without bearing on it ; solicitations
accompanied with the offer of a bribe, of which Rex v. Plympton,
2 Ld. Raymond, 1377, and Rex v. Vaughan, 4 Burr., 2494, are
leading instances. In these the act sought was lawful ; the offer of
a bribe to influence its performance was the unlawful feature.
The adjudications by the highest court of our own State, on
the subject of solicitation to commit crime, touch it only at two
points. They decide that it is a misdemeanor to solicit the com-
mission of murder: Stabler v. Com., 95 Pa. 318; Com. v.
Randolph, 146 Pa, 83 ; and that solicitation to commit fornication
or adultery is not indictable : Smith v. Com., 54 Pa. 209. The
latter case does not, however, go to the length of declaring that
solicitation to commit a misdemeanor is not a misdemeanor. No
general rule on the subject was there laid down. The decision
was based on the difficulty of defining the particular offense
charged in the case ; of determining " what expressions of the face
or double entendres of the tongue, what freedom of manners, are
to be adjudged solicitation ; " and on the principle that " a rule of
law which should make mere solicitation to fornication or adultery
indictable would be an impracticable rule, one that in the present
usages and manners of society would lead to great abuses and
oppressions." It may be added that the act charged was one
that tended only to secret immorality by the parties immediately
involved, and not directly to the public prejudice.
In the broad field lying between the extremes thus adjudi-
cated, our guide must be found in the principles that underlie our
criminal code. To reach just conclusions, we must pursue the
method thus laid down by Mr. Justice Paxson in Com. v. McHale,
V
340 Gases on Criminal Law.
§7 Pa. 397, and applied in that case : " We must look beyond the
eases and examine the principles upon which common law offenses
rest It is not so much a question whether such offenses have
been punished as whether they might have been. . . . We
are of opinion that all such crimes as especially affect public society
are indictable at common law. The testis not whether precedents
can be found in the books, but whether they injuriously affect the
public police and economy."
The distinction, sometimes attempted, between solicitation to
commit a felony and to commit a misdemeanor, is based on an
artificial and not an intrinsic difference. It has received compara-
tively slight judicial recognition. In Reg. v. Ransford, 13 Cox
C. C. 9, it was declared to be without foundation. Indeed, the
statutory classification of crime, as felony or misdemeanor, is gov-
erned by no fixed or definite principle, but is purely arbitrary.
Legislative whim or caprice may alone determine in which category
an offense, not a felony at common law, shall be placed. There is no
reason, arising from the nature of the offenses, why the burning of
another's house shall be classed as a felony, and the burning of
one's own house or other building, with intent to defraud insurers,
as a misdemeanor ; why the larceny of money shall be pronounced
a felony, and its embezzlement only a misdemeanor ; why it shall
be deemed a felony to make counterfeit coin, and but a misde-
meanor to utter it, or a felony to attempt to utter a counterfeit
bank note, and only a misdemeanor to utter counterfeit coin ; why
the possession of ten counterfeit bank notes, with intent to utter
them, shall be declared a felony, and the forgery of a deed merely
a misdemeanor ; or why the forgery of a bank check shall be
made a felony, and the forgery of a promissory note but a mis-
demeanor. With respect to the public police and economy, and
the general interests of society, there are misdemeanors more per-
nicious in effect than some of the felonies. As to the mode and
incidents of trial there is no distinction, except as between offenses
triable exclusively in the oyer and terminer and those within the
jurisdiction of the quarter sessions. As to punishment, trial for
misdemeanor may subject the defendant to punitive consequences
more serious than those to which he is exposed in trial for many
of the felonies, since the penalty is often more severe, and, even if
acquitted, the costs may be imposed upon him. It is obvious that.
Cases on Criminal Law. 341
with respect to the majority of criminal offenses, the distinction
between felonies and misdemeanors rests on no substantial basis,
and that the classification of an offense as a felony or a misde-
meanor affords no just criterion for determining whether solicitation
to its commission is indictable. Under such a test, one may be
punished for soliciting the theft of the most trifling chattel, or the
burning of the most worthless dwelling, yet may with impunity
incite to the embezzlement of millions, or to the laying in ashes of
the largest manufactories, or the entire business quarter of a city.
The only practical and reasonable test is that stated and applied in
Com. V. McHale, supra : the manner in which the act may " affect
the public police and economy ; " and the only logical conclusion
is that all acts which " especially affect public society," to its
injury, are criminal. The act for which the defendant is here
indicted, as thus affecting public society, is the solicitation described
in the indictment.
Argument is scarcely needed to demonstrate that the solicita,-
tion charged in the present case is of a character to injuriously
affect public society and the public police and economy. Except
solicitations to murder and riot, nothing is more calculated to
disorder and terrorize society than incitements to incendiarism;.
Such incitement is a direct blow at security of property and even
■of life. It must therefore be pronounced an indictable offense.
The judgment of the Court below is affirmed}
1 Compare C. v. Willard, 22 Pick., 476 (1839). — Ed.
342 Cases on Criminal Law.
SUFFICIENCY OF THE ACT. {Continued.)
{b) Attempt.
KELLY V. COMMONWEALTH.
Supreme Court of Pennsylvania, 1858.
I Grant's Cases, 484.
Thompson, J. The Commonwealth claimed a conviction on
this indictment, for murder in the first degree, upon two grounds.
First, that the killing was in an attempt to commit a rape on the
person of the daughter of the deceased. Secondly, that it was a
wilful, deliberate and premeditated killing.^
In dealing with this first ground, we think the court presented
the case more strongly against the prisoner than was warranted by
the evidence or the law. An attempt to commit a rape, in which
killing occurs, is necessarily an overt act, indicating the intent and
purpose of the assault, of which clear proof, sufficient to place the
fact beyond a reasonable doubt, should be given. A mere inten-
tion to commit the offense is nothing, unless accompanied by acts
directed towards its accomplishment. The killing, to constitute
the crime of murder, without the specific intent to take life, must
be clearly shown by the prosecution to have occurred in the per-
formance of such acts as should estabhsh the independent substan-
tive crime.
It seems that the unlawful entry of the prisoner and his asso-
ciates into the house of the deceased took place on the night of
the occurrence near midnight. They were all young men, and, it
would appear from the evidence, had been drinking. When first
heard, the deceased said, "they were drunken men." When it
was discovered they were in the room in which the deceased and
his daughter were in bed together, the former jumped out of bed,
and asked, " what they wanted ?" when one of the party inquired
" if the girl was in the house," to which the deceased answered
they should call and see her at another time, and something was
'Jnly so much of this case as relates to attempt is printed.
Cases on Criminal Law. 343
said about drinking whisky, but by whom the. witness could not
remember. She says they then took hold of her father, and she
jumped out of bed, and with a bar of iron struck one of the party
engaged with her father on the arm so severely as to draw from
him an exclamation indicative of pain, after which, it seems, she
received a blow on the arm from the same person, which felled
her. There was no other attempt made upon her then, as we
learn, and the prisoner and his associates left the room, and the
deceased and the witness again retired to bed. Thus far there
was certainly no attempt on the girl ; nor would it have been such
as is necessary to constitute the crime, if the effort had been, as
alleged, for there was scarcely a shadow of proof of it, to get the
deceased out of the room with an intent to return again to the
girl. This would only have been a meditated attempt at most —
not an actual one. We learn from the charge of the court, for it
does not appear on the paper-books, that the prisoner and his
associates returned to the room. A scuffle again ensued between
the deceased and one of the party. Before it began the witness
says she put into the hands of deceased a bar of iron, and with
another piece in her hand fled out of the house to call assistance.
That on going out one of the party caught her by the leg, but she
defended herself, and he let her go. That when she returned she
found the deceased lying on the floor with his skull fractured, of
which he soon died, and the intruders gone.
In all this, where is the evidence of attempted rape? The
fatal blow, according to the testimony of the girl, was given in her
absence. Nothing like an attempt had occurred before she left
the house — not even anything indicative of such design, we should
say, and the parties were gone before she returned. The court, in
the outset of charge, had distinctly submitted to the jury the ques-
tion, whether the prisoner had killed the deceased, and " if in
attempt to perpetrate a rape upon his daughter, he is guilty of
murder in the first degree ;" and on this inquiry, and as evidence,
they direct the jury to consider " for what purpose the prisoner
and his confederates go to that house that night? Was it for for*
nication or rape ? This last can be answered by referring to the
evidence ; of this you will judge." At this point the court direct
the jury to the evidence of the acts of the prisoner and his associ-
ates ; the entry into the house, and accompanying facts, and asks
344 Cases on Criminal Law.
them " if they see anything like fornication or consent " to sexual
intercourse? From this, the question of whether the intent to
commit a rape was not the motive for entry and the motive for
killing, was presented to the jury ; and if so, it is declared to be a
case of murder in the first degree. The court manifestly in all this
substitutes "intent" for "attempt." If murder be committed with
an intent afterwards to commit a rape, and the attempt is never
made, the party would be answerable in the first degree only for
the wilful, deliberate, and premeditated killing, but not for murder
in the attempted rape. The intent is not equivalent to an act
demonstrative of an attempt. The girl testified to no attempt on
her person indicative of any such intent, and she was the only
witness, unless it be what is said by her about being caught as she
fled. But in this she proves no demonstration towards the com-
mission of the crime. Even if she had proved it, it does not
appear that the prisoner caught her, and if he did not, he is not to
be affected by the act of another, unless a common purpose to do
the act attempted was shown to exist between that other and the
prisoner ; it is only in such cases that the act of one shall be
deemed the act of all. The court should have instructed the jury
that acts are necessary to constitute an attempt, and that an attempt
to commit a rape is an ineffectual offer, by force, with intent to
have carnal connection. If such acts, with such intent, were not
proved in the case, then the prisoner could not be convicted on
this branch of it. On the contrary, the court submitted all the
acts of the prisoner to the jury, to find, if they chose, an intent to
commit a rape, which, if found, was to transform acts indifferent,
or at most equivocal in regard to the girl, into an actual attempt
upon her, and thus to change the whole inquiry on the question
of intentional killing ; for if it was perpetrated in an attempt to
commit a rape, it would be murder in the first degree, as we have
said, without regard to whether the killing was by design or acci-
dent. This shows the importance of great care in lajnng the law
down on the question of an attempt. It should be an actual, not
a constructive one.
If the entry into the house of deceased had been shown to
have been burglarious, with the design to commit a rape, and the
breaking and entry were pursuant to such a design, it might have
been considered, under such circumstances, evidence of an attempt.
Cases on Criminal Law. 345
But, to constitute it such, the specific intent to commit the crime
must have existed at the moment of breaking and entering — not
formed afterwards — for if so, the breaking could not be construed
an attempt, as it had not this character in the minds of the prisoner
and his associates at the moment of doing the act.
Judgment reversed, and a new trial awarded}
SIMPSON V, STATE.
Supreme Court of Alabama, 1877.
^^ Alabama, i.
Brickell, C. J. The indictment contains a single count,
charging, in the prescribed form, the defendant with an assault with
intent to rnurder one Michael Ford.^ The offense charged must
be proved, and an essential element of the present offense is not
only an assault with intent to murder, but the specific intent to mur-
der Ford, the person named in the indictment. If the intent was to
murder another, or if there was not the specific intent to murder
Ford, there cannot be a conviction of the aggravated offense charged,
though there may be of the minor offense of assault, or of assault
and battery. Barnes v. State, 49 Miss., 1 7 ; Jones v. State, 1 1 Sm.
& Mar., 3x5 ; Ogletree v. State, 28 Ala., 693 ; Morgan v. State,
33 Ala., 413 ; State v. Abram, 10 Ala., 928.
The intent cannot be implied as matter of law ; it must be
proved as matter of fact, and its existence the jury must determine
from all the facts and circumstances in evidence. It is true, the
aggravated offense with which the defendant is charged cannot
exist, unless if death had resulted, the completed offense would
have been murder. From this, it does not necessarily follow, that
every assault from which, if death ensued, the offense would be
murder, is an assault with intent to murder, within the purview of
the statute, or that the specific intent, the essential characteristic of
the offense, exists. Therefore, in Moore v. State, 18 Ala., 533, an
1 See also Stabler v. C, 95 Pa., 318 (1880).— Ed.
^ Part of the opinion is omitted.
346 Cases on Criminal Law.
affirmative instruction, "that the same facts and circumstances
which would make the offense murder, if death ensued, furnish suf-
ficient evidence of the intention," was declared erroneous. The
Court say : " There are a number of cases, where a kiUing would
amount to murder, and yet the party did not intend to kill. As if
one from the house-top recklessly throw down a billet of wood upon
the sidewalk where persons are constantly passing, and it fall upon
a person passing by and kill him, this would be, by the common
law, murder ; but if, instead of killing him, it inflicts only a slight
injury, that party could not be convicted of an assault with intent
to murder." Other illustrations may be drawn from our statutes;
murder in the first degree may be committed in the attempt to per-
petrate arson, rape, robbery or burglary, and yet an assault com-
mitted in such attempt, is not an assault with intent to murder. If the
intent is to ravish, or to rob, it is under the statute a distinct offense
from an assault with intent to murder, though 'punished with the
same severity. And at common law,if death results in the prosecution
of a felonious intent, from an act malum in se, the killing is murder.
As if A shoot at the poultry of B, intending to shoot them, and by
accident kills a human being, he is guilty of murder, i Russ. Cr.,
540. Yet, if death did not ensue, if there was a mere battery, or a
wounding, it is not, under the statute, an assault with intent to
murder. The statute is directed against an act done, with the par-
ticular intent specified. The intent in fact, is the intent to murder
the person named in the indictment, and the doctrine of an intent
in law different from the intent in fact, has no just application; and
if the real intent shown by the evidence is not that charged, there
can not be a conviction for the offence that intent aggravates, and
in contemplation of the statute, merits punishment as a felony.
Ogletree v. State, supra; Morgan v. State, supra. As is said by
Mr. Bishop, the reason is obvious, the charge against the defendant
is, that in consequence of a particular intent reaching beyond the
act done, he has incurred a guilt beyond what is deducible merely
from the act wrongfully performed ; and therefore, to extract by
legal fiction from this act such further intent, and then add it back
to the act to increase its severity, is bad in law. i Bish. Cr. Law,
§ 5 14.
An application of these general principles, will show that
several of the instructions given by the City Court were erroneous,
Cases on Criminal Law. 347
and some of them misleading, or invasive of the province of the
jury. The sixth, asserts the familiar principle of the law of evidence
that a man must be presumed to intend the natural and probable
consequences of his acts, and from it draws the conclusion, " that
if a man shoots another with a deadly weapon, the law presumes
that by such shooting, he intended to take the life of the person
shot." Whether this instruction would, or would not be correct,
if death had ensued from the shooting, and the defendant was on trial
for the homicide, it is not now important to consider. In a case of
this character, the instruction is essentially erroneous, for if it has
any force, it converts the material element of the offence, the intent
to murder a particular person, into a presumption of law, drawn
from the nature of the weapon, and the act done with it ; while the
intent is a fact which must be found by the jury, and the character
of the weapon, and the act done, are only facts from which it may
or may not be inferred. The weapon used, and the act done,
may in the light of other facts and circumstances, import an intent
to maim, or merely to wound, distinct offences from that imputed
to the defendant ; and maiming or wounding is a probable, natural
consequence of the act done with such weapon. In Morgan v.
State, 33 Ala., 413, the court, at the request of the defendant,
charged the jury, " that they must be convinced beyond all
reasonable doubt, that the prisoner intended to shoot Scrimpshire"
(the prosecutor), "before they can convict the prisoner of an
assault with intent to murder," but added, referring to the particular
facts of the case, "that the presenting of a pistol, loaded and
cocked, within carrying distance, by one man at another, with his
finger on the trigger, in an angry manner, is, in itself, an assault
with intent to murder." This court said : " The explanatory charge
given by the court in this case cannot be supported. It ignores
one of the material facts which constitute the offence for which the
prisoner was on trial. The defendant was not guilty, as charged,
unless he committed the assault, and this act was done with a
special intent to kill and murder the person assaulted." It was said
the facts were proper for the consideration of the jury, and (quot-
ing from Ogletree v. State, supra), that it was competent for them,
in their deliberations, " to act upon the presumptions which are
recognized by law, so far as they are applicable, and their own
judgment and experience, as applied to all the circumstances in
348 Gases on Criminal Law.
evidence. It does not, however, result as a conclusive presump-
tion at law, from the facts supposed in the charge, that the accused
had the intent to take the life of Scrimpshire : the surrounding cir-
cumstances should have been considered by the jury ; and unless
the jury were convinced that the prisoner entertained the particular
intent to take the life of his adversary, then the prisoner could not
be convicted of the higher crime. The particular intent reaches
beyond the act done, and is a fact to be found preliminary to con-
viction, as necessary to the other fact itself, viz : that the assault
was committed. In other words, while the law permits and com-
mands juries to indulge all reasonable inferences from the facts in
proof, it does, propria vigore, infer the one fact from another."
The result is that the judgment of the City Court is reversed,
and the cause remanded. The prisoner will remain in custody
until discharged by due course of law.-^
COMMONWEALTH v. PEASLEE.
Supreme Judicial Court of Massachusetts, 1901.
177 Massachusetts, 267.
Holmes, C. J.^ This is an indictment for an attempt to burn
a building and certain goods therein, with intent to injure the
insurers of the same. Pub. Sts., c. 210, § 8. The substantive
offence alleged to have been attempted is punished by Pub. Sts., c.
203, § 7. The defence is that the overt acts alleged and proved
do not amount to an offence. It was raised by a motion to quash
and also by a request to the judge to direct a verdict for the
defendant. We will consider the case in the first place upon the
evidence, apart from any question of pleading, and afterwards will
take it up in connection with the indictment as actually drawn.
The evidence was that the defendant had constructed and
arranged combustibles in the building in such a way that they were
^Accord : Reg v. Donovan, 4 Cox C. C, 401 (1850) ; see also C. v.
Brosk, 8 Dist. Rep. (Pa.) 638 (1899)— Ed.
2 The opinion only is printed.
Cases on Criminal Law. 349
ready to be lighted, and if lighted would have set fire to the build-
ing and its contents. To be exact, the plan would have required a
candle which was standing on a shelf six feet away to be placed on
a piece of wood in a pan of turpentine and lighted. The defendant
offered to pay a young man in his employment if he would go to the
building, seemingly some miles from the place of the dialogue, and
carry out the plan. This was refused. Later the defendant and
the young man drove toward the building, but when within a quar-
ter of a mile the defendant said that he had changed his mind and
drove away. This is as near as he ever came to accomplish-
ing what he had in contemplation.
The question on the evidence, more precisely stated, is
whether the defendant's acts come near enough to the accom-
plishment of the substantive offence to be punishable. The statute
does not punish every act done toward the commission of a crime, .
but only such acts done in an attempt to commit it. The most
common types of an attempt are either an act which is intended
to bring about the substantive crime and which sets in motion
natural forces that would bring it about in the expected course of
events but for an unforeseen interruption, as in this case if the
candle had been set in its place and lighted but had been put out by
the police, or an act which is intended to bring about the sub-
stantive crime and would bring it about but for a mistake of
judgment in a matter of nice estimate or experiment, as when a
pistol is fired at a man but misses him, or when one tries to pick a
pocket which turns out to be empty. In either case the would-be
criminal has done his last act.
Obviously new considerations come in when further acts on
the part of the person who has taken the first steps are necessary
before the substantive crime can come to pass. In this class of
cases there is still a chance that the would-be criminal may change
his mind. In strictness, such first steps cannot be described as an
attempt, because that word suggests an act seemingly sufficient to
accomplish the end, and has been supposed to have no other mean-
ing. People V. Murray, 14 Cal., 159, 160. That an overt act,
although coupled with an intent to commit the crime commonly
is not punishable if further acts are contemplated as needful, is
expressed in the familiar rule that preparation is not an attempt
But some preparations may amount to an attempt. It is a ques-
350 Cases on Criminal Law.
tion of degree. If the preparation comes very near to the accom-
plishment of the act, the intent to complete it renders the crime so
probable that the act will be a misdemeanor although there is still
a locus penitenticB in the need of a further exertion of the will to
complete the crime. As was observed in a recent case, the degree
of proximity held sufficient may vary with circumstances, including
among other things the apprehension which the particular crime is
calculated to excite. Commonwealth z/. Kennedy, 170 Mass., 18,
22. (See also Commonwealth w. Willard, 22 Pick., 476.) A few
instances of liability of this sort are mentioned on the page cited.
As a further illustration, when the servant of a contractor had
delivered short rations of meat by the help of a false weight which
he had substituted for the true one, intending to steal the meat
left over, it was held by four judges, two of whom were Chief
Justice Erie and Mr. Justice Blackburn, that he could be con-
victed of an attempt to steal. Regina v. Cheeseman, L. &. C,
140; S. C, 10 W. R., 255. So lighting a match with intent to
set fire to a haystack, although the prisoner desisted on discover-
ing that he was watched. Regina v. Taylor, i F. &. F. , 5 1 1 . So
getting into a stall with a poisoned potato, intending to give it to
a horse there, which the prisoner was prevented from doing by his
arrest. Commonwealth v. McLaughlin, 105 Mass., 460. See
Clark V. State, 86 Tenn., 511. So in this Commonwealth it was
held criminal to let a house to a woman of ill fame with intent
that it should be used for purposes of prostitution, although it
would seem that the finding of intent meant only knowledge of
the intent of the lessee. Commonwealth z^. Harrington, 3. Pick.,
26. See Commonwealth v. Willard, 22 Pick., 476, 478. Com-
pare Brockway v. People, 2 Hill, 558, 562. The same has been
held as to paying a man to burn a barn, whether well laid as an
attempt or more properly as soliciting to commit a felony. Com-
monwealth V. Flagg, 135 Mass., 545,549. State v. Bowers, 35
So. Car., 262. Compare Regina z/. Williams, i C. & K., 589;
S. C, I Denison, 39. McDade v. People, 29 Mich., 50, 56.
Stabler v. Commonwealth, 95 Penn. St., 318. Hicks v. Common-
wealth, 86 Va., 223.
On the other hand, making up a false invoice at the place of
exportation with intent to defraud the revenue is not an offence
if not followed up by using it or attempting to use it. United
Cases on Criminal Law. 351
States V. Twenty-eight Packages, Gilpin, 306, 324. United States
V. Riddle, 5 Cranch, 311. So in People v. Murray, 14 Cal., 159,
the defendant's elopement with his niece and his requesting a
third person to bring a magistrate to perform the marriage cere-
mony, was held not to amount to an attempt to contract the mar-
riage. But the ground on which this last decision was put clearly
was too broad. And however it may be at common law, under a
:statute like ours punishing one who attempts to commit a crime
•"and in such attempt does any act towards the commission of such
offence" (Pub. Sts., c. 210, § 8), it seems to be settled elsewhere
that the defendant could be convicted on evidence like the present.
People V. Bush, 4 Hill, 133, 134. McDermott z/. People, 5 Par-
ker Cr. Rep. 102. Griffin v. State, 26 Ga., 493. State v. Hayes,
78 Mo. 307, 316. See Commonwealth v. Willard, 22 Pick., 476.
People V. Bush is distinguished in Stabler v. Commonwealth as a
decision upon the words quoted. 95 Penn. St., 322.
Under the cases last cited we assume that there was evidence
of a crime and perhaps of an attempt, — ^the latter question we do
not decide. Nevertheless, on the pleadings a majority of the court
is of opinion that the exceptions must be sustained. A mere col-
lection and preparation of materials in a room for the purpose of
setting fire to them, unaccompanied by any present intent to set the
fire, would be too remote. If the accused intended to rely upon his
own hands to the end, he must be shown to have had a present
intent to accomplish the crime without much delay, and to have
had this intent at a time and place where he was able to carry it
out. We are not aware of any carefully considered case that has
gone further than this. We assume without deciding that this is
the meaning of the indictment, and it would have been proved if
for instance the evidence had been that the defendant had been
frightened by the police as he was about to light the candle. On the
other hand, if the offence is to be made out by showing a prepara-
tion of the room and a solicitation of some one else to set the fire,
which solicitation, if successful, would have been the defendant's
last act, the solicitation must be alleged as one of the overt acts.
It was admissible in evidence on the pleadings as they stood to
show the defendant's intent, but it could not be relied on as an
overt act unless set out. The necessity that the overt acts should
be alleged has been taken for granted in our practice and decisions.
352 Cases on Criminal Law.
(see e. g. Commonwealth v. Sherman, 105 Mass., 169 ; Common-
wealth V. McLaughlin, 105 Mass., 460, 463 ; Commonwealth
V. Shedd, 140 Mass., 451, 453), and is expressed in the
forms and directions for charging attempts appended to St. 1899,
c. 409, § 28 and § 2. Commonwealth v. Clark, 6 Gratt., 675.
State z/. Colvin, 90 No. Car., 717. The solicitations were alleged
in McDermott v. People. In New York it was not necessary to
ay the overt acts relied upon. Mackesey v. People, 6 Parker Cr,
Rep., 114, 117, and New York cases, supra. See 3 Encyc. PI. &
Pr., "Attempts," 98. A valuable collection of authorities con-
cerning the crime will be found under the same title in 3 Am. &
Eng. Encyc. of Law (2d ed.). If the indictment had been properly
drawn we have no question that the defendant might have been
convicted.
Exceptions sustained}
MARLEY V. STATE.
Supreme Court of New Jersey, 1895.
58 New Jersey Law, 207.
Beasley, Chief Justice.^ The defendants were indicted for
incurring an obligation in behalf of the county in excess of the
legal limit. The indictment sets out, in detail, the several acts
done by them to that end, and the proofs corresponded with such
allegations. The case, therefore, that was made by the indictment
was in all respects proved. In this situation the trial court con-
cluded that the series of acts so done by the defendants was, as a
matter of law, wholly nugatory ; that such acts did not and could
not impose any legal obligation on the county.
This construction of the legal question thus involved, having
been adopted at the trial, the jury was then instructed, as we have
1 Seealso, U. S. v. Stephens, 3 Sawy., 116 (1882) ; Cornwell v. Asso-
ciation, 69 N. W. (N. D.) 191 (1896.).— Ed.
* Part of the opinion only is printed.
Cases on Criminal Law. 353
seen, that although they would not be warranted to find the defend-
ants guilty of the crime thus charged, they still had the right, if
the, evidence established the fact, to find that they had attempted to
commit it.
This theory of the case, we think, is fallacious ; it is demon-
strably erroneous from two considerations.
The first of these is, that the decision of the trial judge, that
the facts proved did not show the imposition of an obligation on
the county, was tantamount to a decision that the indictment itself
did not charge any offence ; for the facts charged and the facts
proved were identical. It would seem to be self-evident that if
the case made by the record was wholly established by the evidence,
and the latter, in a legal point of view, was nugatory, it neces-
sarily follows that the case as presented in the record was equally
nugatory. Therefore, accepting the view of the judge at the
trial, and from which we do not dissent, it is an unavoidable corol-
lary that the defendants could not be convicted of an attempt to
commit a crime that was not charged. The statutory regulation
in question is, by its very terms, applicable to the situation when
the indictment exhibits on its face a criminal offence. In the
present instance this essential is lacking, according to the view of
the law taken at the trial.
On this ground also the judgment is invalid.
The same result must obtain from another aspect of the case.
It has been entirely settled by judicial decisions that the act
which it is declared that these defendants attempted to do cannot be
done by the method stated in the indictment. As the law has been ex-
pounded, the board of freeholders, to which they regularly belonged,
under the existent circumstances, could not impose upon the
county the obligation in question. Siedler v. Chosen Free,
holders, &c., 10 Vroom, 632. And so far was this doctrine extended
that in the Circuit Court of the United States in the case of Cramp-
ton V. Zabriskie, lOi U. S., 601, it was held that where the county
bonds had been given for lands conveyed to the county, such
bonds being in excess of the funds appropriated, such transaction
is, in all its parts, utterly void, and a decree was accordingly made
requiring the vendor of the property to accept a reconveyance
and to return the bonds so given in payment of the purchase-
money. This decree was affirmed in the Supreme Court of the
354 Cases on Criminal Law.
United States; on the ground that the board of freeholders could
not, in the mode adopted, incur any obligation for the county be-
yond its income previously provided by taxation. And this, as has
been shown, was the doctrine in accordance with which the present
case was tried.
Looking, then, to this datum it is obvious that the defendants
have been convicted of an attempt to commit a misdemeanor
which was a legal impossibility, and which they knew to be such.
Such a procedure would appear to be inconsistent with the
fundamental principles of law applicable to the subject.
An intent to commit a crime is not equivalent to an attempt to
commit it, for the purpose must be accompanied with some sub-
stantive act, or series of acts, tending towards its accomplishment. _
Mr. Bishop, with his usual explicitness and clearness, says :
"Another principle concerning attempt is that, whatever a man's
intent may be, he is not indictable unless there is some adaptation,
real or apparent, in the thing done to accomplish the thing in-
tended." I Bish. Cr. L., § 516. So, speaking of the intent, "every-
one being conclusively presumed to understand the law, no man
can legally intend what is legally impossible." Id., § 518.
In the light of such a theory it becomes plain that these de-
fendants, even if the intent to commit the offence charged can be
imputed to them, did, in legal contemplation, no act towards the
accomplishment of such purpose, for every act they did was, in
the eye of the law, an absolute nullity. Not one of them, there-
fore, could tend to carry into effect any criminal project.
It should be noticed that the principle here introduced is to be
distinguished from the rule that is applicable to the case of a person
designing to perpetrate a crime, when he cannot effect it by reason
of the existence of some fact unknown to him at the time. The
cases are collated and the principle elucidated in the recent case of
People V. Gardner, 38 N. E. Rep., 1003. State v. Wilson, 30
Conn., 500.
As it may suggest itself to a person looking into the subject
thus considered that the rule adopted by the trial judge in its ap-
plication to the primary question before him is not consistent with
the decision in State v. Halsted, 10 Vroom, 402, 12 Id., 552,
it is proper to say that such topic was not in the reported case dis-
cussed by counsel, nor was it considered or decided by the court.
Cases on Criminal Law. 355
The proposition that the freeholders have not the power to create
an obligation binding on the county by the methods now in ques-
tion has been established by more recent decisions.
Let the judgment be reversed.
CLARK V. STATE.
Supreme Court of Tennessee, 1888.
86 Tennessee, 511.
FoLKES, J. This is an indictment for attempt to commit a
larceny. There was a conviction and sentence of one year in the
penitentiary. Motion for new trial and in arrest of judgment being
made and overruled, the defendant has appealed in error.^
The next error assigned is to the charge of the Court in this :
" If his purpose was to steal when he opened the drawer, and his
opening it was a part of the act designed by him for getting
possession of the prosecutor's money, he would be guilty of an
attempt to commit larceny, even though at that particular time
there was no money in the cash-drawer."
The proof shows that the defendant was detected by the
prosecutor in the act of opening the cash-drawer of the latter's
store, having thrown himself across the counter for that purpose,
he being alone in the front part of the store at the time — the
prosecutor being in the rear waiting on a customer, and being
hidden from defendant's view by a screen. When thus detected,
and hallooed at by the prosecutor, the defendant hurriedly left the
store.
The proof leaves it in doubt whether or not there was any
■ • The accused being under fourteen' years of age, and conclusively pre-
sumed to be incapable of committing the crime of rape, it logically follows,
as a plain, legal deduction, that he was also incapable in law of an attempt to
commit it. He could not be held to be guilty of an attempt to commit an
offence which he was physically impotent to perpetrate." Riley, J., in Foster
V. C.,96 Va., 306(1898). Contra C. v. Green, 2 Pick.380 (1824).— Ed.
' Part of the opinion is omitted.
3S6 -Cases on Criminal Law.
money in this particular drawer at the time the attempt was made.
•It was early in thfe morning, and the drawer had been emptied the
evening before.
The Court had stated to the jury that the State claimed that
there was money in the drawer at the time of the alleged attempt
and that this was denied by the defendant, and that this was one
of the questions of fact that they must determine, and that they
must determine from the proof what was the purpose and intention
of the prisoner in opening the cash-drawer ; and if they found that
the defendant believed there was money or other valuables in said
drawer, and his purpose in opening the same was to steal its con-
tents, then he would be guilty of an attempt to commit larceny,
whether there were money or other valuables in the drawer at the
time or not.
There is no error in this record. The act averred and proven
is sufficient.
The direct question here presented has never been passed
upon by this Court, but it is by no means one without authority.
It has received much discussion in the text-books, and in the
adjudged cases froni other courts.
The English cases are conflicting. In Reg. v. Collins, Leigh-
& C, 471, it was held there could be no attempt to pick the
pocket of a person who had no money at the time in her pocket ;
while in Reg. v. Goodhall, i Den. C. C, 187, it was held an
attempt to produce a miscarriage could be committed on a woman
supposed to be, but not in fact, pregnant.
It appears to us that these cases cannot be reconciled,
although Mr. Heard, in his second edition of Leading Criminal
Cases, Vol. II., pp. 482-483, has attempted to do so. We are
constrained to agree with Mr. Bishop, that "these differing opinions
must have sprung from opposite views in the two benches of
Judges." See note i to § 741, Bishop's Cr. L., 7th Ed..
The American cases seem to be uniform, or at least substan-
tially so, for here the few conflicts are more apparent than real.
In Commonwealth v. Rogers, 5. S. & R., 463, the Penn-
sylvania Court held that an indictment for assault with intent to
steal from the pocket is good, though it contains no setting out of
anything in the pocket to be stolen. Duncan, J., in delivering
the opinion of the Court, said : "The intention of the person was
Cases on Criminal Law. 357
to pick the pocket of whatever he found in it ; and although there
might be nothing in the pocket, the intention to steal is the same."
So in Massachusetts, under a statute differing in terms but the
same in substance as our own hereinabove quoted, it was held that
the indictment need not allege, and the prosecutor need not prove,
that there was in the pocket anything which could be the subject
of larceny. Commonwealth v. McDonald, 5 Cush., 365. See also
Commonwealth v. Jacobs, 9 Allen, 274.
To the same effect is State v. Wilson, 30 Conn., 500.
So in Indiana it has been held that an assault on- one with ,
intent to rob him of, his money may be committed, though he has
no money in possession at the time. Hamilton v. State, 36
Ind. 280.
If an indictment for an attempt to steal the contents of a
trunk or room would not be good, where it transpired that there
was nothing in the trunk or room, then it would seem to follow
that the indictment, in case where there were goods in the trunk
or room, would have to allege what particular goods the thief
purposed to steal ; and if necessary to allege, it is necessary to
prove, and how could this be proven where there was a variety of
different goods, and the thief was arrested before he had laid hands
upon any article ?
Again : if a thief is caught with his hand in your pocket
before he can grasp any of its contents, and it is found that the
pocket contains both money and a watch, how can it be proven
that he intended to steal both, and if not both, which ?
And in the case last put, is there any more of an attempt to
steal, the thief being ignorant of the presence of the watch or •
money, than there would be had he, with similar intent and igno-
rance, placed his hand in an empty pocket ?
In each case there is the substantive and distinct offense as
prescribed by the statute. There is the criminal intent, and an
effort made to carry out the intent to the point of completion,
interrupted by some unforeseen impediment or lack outside of
himself, special to the particular case and not open to observation,
intervening to prevent success without the abandonment of effort
or change of purpose on the part of the accused.
As said by Mr. Bishop : " It being accepted truth that the
defendant deserves punishment by reason of his criminal intent, no
358 Cases on Criminal Law.
one can seriously doubt that the protection of the public requires
the punishment to be administered, equally whether, in the unseen
depth of the pocket, etc., what was supposed to exist was really
present or not. " i Bishop Cr. L., Sec. 741.
The community suffers from the mere alarm of crime.
Again : " Where the thing intended (attempted) is a crime,
and what is done is of a sort to create alarm — in other words, excite
apprehension that the evil intended will be carried out — the incipi-
ent act which the law of attempt takes cognizance of is in reason
committed." i Bishop Cr. L., Sec. 742.
The true legal reason for the conclusion reached is that the
defendant, with the criminal intent, has performed an act tending
to disturb the public repose. lb.. Sec, 744.
Mr. Wharton's views on this, at one time, perplexing question
are in accord with Mr. Bishop. See i Whart. Cr. L., Sees. 182,
183, 185, 186, and 192, 9th Ed.
Let the judgment be affirmed}
SUFFICIENCY OF THE ACT. {Continued:)
{c) Conspiracy.
STATE V. BUCHANAN.
Court of Appeals of Maryland, 182 i.
5 Harris and Johnson, 317.
This was an indictment charging the defendants in the second
count with a conspiracy falsely, fraudulently and unlawfully, by
wrongful and indirect means, to cheat, defraud and impoverish the
^ Seealso St. v. Glover, 27 S. C. 602 (1888).— Ed.
' |If an assault should be made on a man dresspd as a woman, with intent
to ravish, the assailant believing the person assaulted to be a woman, he could
not be convicted of an attempt to ravish, because in such a case the com-
mission of the crime of rape would be a legal impossibility.' ' FoUelt, T. , in
People V. Gardiner, 73 Hun, 66 (1893).
Cases on Criminal Law. 359
president, directors and company of the Bank of the United
States. To this indictment there was a demurrer that the matter
contained in the indictment was not sufficient to sustain the prose-
cution. The county court ruled the demurrer good [Dorsey, C.
J. dissenting], and discharged the defendants. The present writ of
error was brought on the part of the state.
The case was argued in this court before Chase, C. J. Bu-
chanan, Earle and Martin, JJ.
Chase, C. J.^ I think it may be assumed as a position which
cannot be controverted, and is free from doubt, that the common
law of England, as it was understood at the time of the declaration
of rights, was the law of Maryland ; and I think the position is
equally clear, that it must be ascertained by the writings of learned
men of the profession, by the judicial records and adjudged cases
of the courts of England.
The questions now occur. Do the facts contained in the in-
dictment constitute the crime or offence of conspiracy ? And is
conspiracy an offence at common law, indictable and punishable as
such ?
Sergeant Hawkins, in his Pleas of the Crown, ch. 72, in de-
fining conspiracy at common law, makes use of strong and explicit
language, and says there can be no doubt but that all confedera-
cies whatsoever, wrongfully to prejudice a third person, are highly
criminal at common law ; as where divers persons confederate
together by indirect means to impoverish a third person. This
definition is corroborated and supported by adjudged cases in the
courts in England, and especially in the court of King's Bench.
In I Lev. 125, I Burn's Justice, 355, The King v. Sterling and
others. Brewers of London. — Information for unlawfully conspiring
to impoverish the excisemen by making orders that no small beer,
called gallon beer, should be made for a certain time, &c. The
whole court concurred in the opinion, and gave judgment for the
king.
The statute 33 Edw. i, de conspiratoribus, was made in affirm-
ance of the common law, and is a final definition of the instances
or cases of conspiracy mentioned in it ; but certainly it does not
comprehend all the cases of conspiracy at the common law,
^The indictment is abridged and the argument of counsel and the con«
curring opinion of Buchanan, J. are omitted.
360 Cases on Criminal Law.
which is most apparent from the adjudged cases of the courts of
England on that subject.
I consider the adjudications of the courts of England, prior to
the era of the independence of America, as authority to show what
the common law of England was, in the opinion of the judges of
the tribunals of that country, and since that time, to be respected
as the opinions of enlightened judges of the jurisprudence of Eng-
land.
The better opinion appears to be, that a conspiracy to do an
unlawful act is an indictable offence, although the object of the
conspiracy is not executed.* In this case the conspiracy to cheat,
defraud and impoverish, the Bank of the United States, by appro-
priating the moneys, promissory notes, and funds of the bank, to
the use of the accused, has been proved by the admission and con-
fession of the defendants, and a consummation of all the overt acts
has been fully established.
The Poulterer's case, 9 Coke, 56, 57. — The falsa alligantia is
a' false binding, each to the other, by bond or promise to execute
some unlawful act. Before the unlawful act executed, the law
punishes the coadjunction, confederacy or false alliance, to the end
to prevent the unlawful act — quia quando aliquid prohibetur, pro-
hibetur et id per quod pervenitur ad illud. Et effectus punitur licet
non sequatur effectus ; and in these cases the common law is a
law of mercy, for it prevents the malignant from doing mischief,
and the innocent from suffering it The defendants were punished
by fine and imprisonment.
I think it is established by the decisions of the courts of Eng-
land, that a conspiracy to cheat is an offence indictable and punish-
able at common law. Rex v. Wheatly, 2 Burr. 11 25. A cheat or
imposition by one person only is not indictable at common law,
but a conspiracy to cheat by two or more is indictable at common
law, because ordinary care and caution is no guard against it. In-
dictment against Macarty and others, for a combination to cheat in
imposing on the prosecutor stale beer mixed with vinegar, for port
>In some States by statute, an overt act is necessary in specified cases
to constitute the crime of conspiracy. See P. -v. Daniels, 105 Cal., 262
(1894); St. V. Clary, 64 Me., 369 (1875); Wood z/. St., 47 N. J. L., 180
(1885) ; P. V. Flack, 125 N. Y., 324 (1891) ; U. S. v. Barrett, 65 Fed., 62
(1894).— Ed.
Cases on Criminal Law. 361
wine, 6 Mod. 301. Indictment against Cope and others, for a
conspiracy to ruin the trade of the prosecutor by bribing his ap-
prentices to put grease into the paste, which had spoiled his cards,
I Strange, 144. Indictment against Kinnersley and Moore, for
a conspiracy to charge Lord Sunderland with endeavoring to
commit sodomy with said Moore, in order to extort money from
Lord Sunderland. The whole court gave judgment in support of
the indictment, and punished Kinnersley by fine, imprisonment,
&c. and sentenced Moore to stand in the pillory, suffer a year's
imprisonment, and to give security for his good behavior, i Stra.
193, 196. Indictment against Rispal, 3 Burr. 1320. — The in-
dictment sets forth that Rispal and two others, did wickedly
and unlawfully conspire among themselves, falsely to accuse
John Chilton with having taken a quantity of human hair out of a
bag, &c., for the purpose of exacting and extorting money from the
said John Chilton. The court were of opinion, that the indictment
was well laid, and that the gist of the offence is the unlawful con-
spiring to injure Chilton by this false charge.
A combination among laborers or mechanics to raise their
wages, is a conspiracy at common law, and indictable, 8 Mod.
10, although lawful for each separately to raise his wages.
I consider the doctrine so firmly established by the decisions
■of the courts of England, prior to the era of our independence,
that a combination or confederacy to do an unlawful act is a con-
spiracy indictable and punishable at common law, that I have
deemed it unnecessary to refer to all the cases relative to this
question, and therefore have contented myself with citing some of
those which appear to me most apposite.
The opinion of Lord Ellenborough in The Kingz/. Turner and
others, 13 East, 230, does not impugn, but strongly sanctions and
confirms this doctrine. He says the cases of conspiracy have gone
far enough, he should be sorry to push them still further. The
charge in the indictment was for committing a civil trespass. He
also says, all the cases in conspiracy proceed on the ground that
the object of the conspiracy is to be effected by some falsity.
I am of opinion that the judgment be reversed, and the
demurrer overruled. Judgment reversed.
362 Cases on Criminal Law.
REX V. BYKERDIKE.
Lancaster Assizes, 1832,
r Moody d^ Robinson, 179.
First count of the indictment charged that R. Bykerdike, with
divers others, &c., did conspire, combine, confederate, and agree
unlawfully to intimidate, prejudice, and oppress one John Garforth
in his trade and occupation, as agent for a certain colliery, to wit,
&c., and to prevent the workmen of the said J. G. from continuing
to work in the said colliery.
Second count laid a conspiracy to oppress and injure Joseph
Jones and others, partners in a certain colliery, to wit, &c.; and to
prevent the workmen in the employ of the said J. J. and others,
his partners, from continuing to work at the said colliery, and com-
pel the said J. J. and others, his partners, to discharge the said
workmen in their employ.
Jones was an owner of the Fairbottom colliery, Garforth was
agent for the colliery. Seven colliers had been summoned
before a magistrate by Garforth for refusing to work. It appeared
that this was done at their own request, as they were afraid to^
work except under the appearance of being compelled to do so..
The body of the other men met, having taken certain oaths, and
agreed upon a letter addressed to Garforth, to the effect that all
workmen in Garforth's employ would "strike in fourteen days
unless the seven men were discharged from the colliery." The
letter concluded, " By order of the board of directors for the body
of coal miners. Fairbottom Colliery." ^
Patteson J. told the jury that a conspiracy to procure the
discharge of any of the workmen would support the indictment,
which did not necessarily lay the intent as to all the workmen :
and, if it did, that it was still a question whether the facts would
not have proved it as to all. Further, that the statute never meant
to empower workmen to meet and combine for the purpose of dic-
tating to the master whom he should employ ; and that this com-
pulsion was clearly illegal.
The defendant was convicted.^
^ Argument of counsel is omitted.
"Accord: St. v. Donaldson, 32 N. J. L., 151 (1867).
Cases on Criminal Law. 363
COMMONWEALTH v. SHERIFF.
Court of Quarter Sessions of Philadelphia, 1881.
15 Philadelphia, 393.
Habeas corpus. Opinion delivered November 5, 1881, by
Allison, P. J. The defendants were charged, on oath of
Michael T. Benerman, with having unlawfully conspired to injure'
the firm of Sherman & Co., by molesting, intimidating and annoy-
ing said firm in their business ; and were required to give bail in
the sum of ;^6oo each, to answer said charge at the present
October term of the Quarter Sessions.
The defendants, representing a trades union association,
called upon a member of the firm at their office or place of busi-
ness, and gave notice that the association had decided upon an
increase of wages to be paid to journeymen printers employed in
the offices of this city, and in case the increased rates were not
paid by the said firm to the persons in their employ, there would
be a strike on the part of their employes. The demand for
increase of compensation having been refused, the defendants
proceeded to the office or shop of the complainants, where their
journeymen were at work, and notified them that the advanced
rate of compensation having been refused there would be a strike,
or that a strike was ordered, and that after that day, they should
cease to work for Sherman & Co., until their wages had been
advanced to the standard fixed by the union. All of the work-
men, with one exception, including the foreman of the office, were
members of the union, and, according to the law of their organiza-
tion, were required to obey the rules and regulations of the body
of which the defendants were the duly appointed representatives.
Does this conduct on the part of defendants amount to an unlaw-
ful conspiracy, for which they may be indicted and placed on trial ?
Prior to the act of June 14, 1872, and the supplemental act
of April 20, 1876, the law, as then settled, would have required
this question to be answered in the affirmative. A conspiracy of
workmen to raise wages by combining to coerce other persons to
conform to rules adopted by such combination, regulating the price
of labor, and carrying such rules into effect by acts and declarations
tending to control the will and conduct of others, constituted a
364 Cases on Criminal Law.
criminal, and, therefore, an indictable offence ; 3 Wharton Cr. L.,
sec. 2322; Bishop's Cr. L., sees. 230, 231. This is equally true,
whether the conspiracy was intended to coerce the free will and
freedom of action of workmen, or employer. In 3 Russell on
Crimes, the law, as there stated, is: "A combination to obstruct
others in carrying on their business and forcing them to submit
to a book of prices, inducing workmen to leave their employer's
service, the purpose being to obstruct the prosecutors in their
manufacture and injure them in their business, and thus force their
consent, would be a violation of law, which would be indictable."
In Commonwealth v. Carlisle, Brightly's Rep., 40, Gibson, J., said :
" A combination is criminal whenever the act to be done has a
necessary tendency to prejudice the public or oppress individuals
by unjustly subjecting them to the power of the confederates.
Where the purpose is injurious or unlawful, the gist of the offence
is the conspiracy." Morris Co. v. Barclay Co., 18 P. F. Smith,
186, and numerous illustrations of the doctrine there cited by
Agnew, C. J.
Admitting the law to have been clearly established, so that it
would have subjected the defendants to indictment, for the com-
bination and acts done in pursuance of the conspiracy, as proved
on the hearing in this case, what is their standing now before or
under the law of Pennsylvania, as affected by the legislation of
1872 and 1876?
The act of 1872, Purdon, 351, declares that it shall be lawful
for workingmen, acting either as individuals or as members of any
club, society or association, to refuse to work for any person,
whenever, among other causes recited in the act, to continue such
work would be contrary to the rules or regulations of such organ-
ization to which they may belong, and that such refusal shall not
subject them to prosecution or indictment for conspiracy. This act
sweeps away in a few words nearly all of the law which had been
long established in England, and adopted in this country, touching
organizations or combinations of workingmen, having for their
object the regulation of amounts to be paid to them for their work,
by combination in clubs or societies. That which had been held
to be contrary to law is declared to be lawful, and that which
before would have subjected workingmen to criminal prosecution,
the act says, may be done without incurring the risk of indictment.
Cases on Criminal Law. 365
It is, therefore, no longer unlawful to combine and organize and
adopt regulations having for their object the increase of wages or
the consideration to be paid for labor. The effect of such com-
bination may be to prejudice the interests of the community, and
may tend to injure individuals in their business by causing the
employed to cease to work for an employer, and thus compel him
to submit to a book or standard of prices, which had been fixed by
workingmen who had combined and organized for that purpose
The act contains, however, the material proviso that whoever shal.
hinder persons who desire to labor for their employers from so
doing, or other persons from being employed as laborers, shall still
be subject to prosecution and punishment, as for a criminal con-
spiracy. What constituted such hindrance was not defined, and it
was for the pupose of removing all ambiguity connected with the
word hinder, in the act of 1872, that the supplemental law of April
20, 1876, was passed, which declares that the construction to be
given to the proviso contained in the act of 1872 shall be that the
use of lawful and peaceful means, having for their object a lawful
purpose, shall not be regarded as " in any way hindering " persons
who desire to labor ; and that the use of force, threat or menace
of harm to persons or property shall alone be regarded as in any
.way hindering persons who desire to labor for their employers from
so doing, or other persons from being employed as laborers.
Under this statement of the law of Pennsylvania, as it stands
to-day in full force, the only question for our consideration is, do
the acts of the defendants, representing and acting in behalf of a
labor society, club or organization, subject them to indictment?
Does calling together upon the firm of Sherman & Co., demand-
ing an increase of wages for the journeymen printers employed by
the firm, with notice that a refusal would result in a strike of the
workmen, followed by the defendants going together to the work-
shop of the prosecutors and notifying the journeymen that a strike
was ordered, constitute the use of force, threat or menace of harm
to the persons or property of the firm, or to the members of the
firm of Sherman & Co., or to their employes ? Are these means
otherwise than lawful and peaceful, and had they for their object
a lawful purpose ? We are unable to see wherein they offend
against the law. If laborers may now lawfully combine, and, as
•members of such combination, refuse to work for an employer,
366 Cases on Criminal Law.
when, in their opinion, the wages paid to them are insufficient ; if
they may now lawfully refuse to work, when to do so would be
contrary to the rules, regulations or by-laws of any association to
which they may belong, how can it be considered as amounting to
force, threat or menace of harm, for two or more persons author-
ized to act for such association, to say to an employer that a rule,
by-law or regulation of the association required the payment of
increased wages, and that, on refusal to make such payment, their
workmen were, by virtue of their membership of a lawful society
and its regulations, required to stop work ? It is true, that strik-
ing, as it is called, or refusing to work, might, and probably would,
result in harm to the business of Sherman & Co., but that is the
result of what the workmen may now lawfully do in their asso-
ciated capacity, and does not constitute a threat or menace of harm
in the sense in which these terms are to be understood as they are
used in the act of 1876. The fact is not to be overlooked that it
had too often been a matter of just complaint that workmen resorted
to actual force, to threats and menace of injury to persons and
property in the enforcement of a demand for an advanced rate of
wages. Upon this, the law always frowned. Such acts were always
illegal. When done by agreement between two or more persons,
they amounted to overt acts, growing out of a criminal conspiracy,
which tended to the injury of the community and to the subver-
sion of individual rights of persons and property. This was the
wrong referred to in the act of 1876, which it was declared would
subject the offenders to punishment in the future, as it had in the
past. Such acts were declared to be outside of the protection
contemplated by the legislation which we are now considering,
because such means are neither lawful nor peaceful, and because
they are calculated to improperly hinder persons who desire to
labor for their employers from so doing, and to prevent other per-
sons from being employed as laborers.
It was further urged on behalf of the commonwealth that the
intrusion of the defendants into the shop or workroom of the
prosecutors was in itself a trespass, and, therefore, illegal, and that
the means employed to carry into effect the purposes of the
defendants are not sanctioned by the act of 1876. But this prop-
osition is not borne out by the testimony in the cause ; for it has
not been shown that visits like the one made by defendants —
Cases on Criminal Law. 367
workmen of the same craft going to shops where other workmen
are employed — are not, at least, with the implied permission of
the employers. It is not pretended in this case that defendants
■were forbidden to enter the shop, or that they were ordered to
depart after they had entered, or that their conduct was not peace-
able and orderly. The foreman having charge of the shop was
present, and knew of the presence of the defendants and of the
object of their visit. To this, he did not object, and, in so far as
he represented the prosecutors, may be said to have consented to,
if he did not approve of all that was said and done. Reaching the
conclusion that the defendants are not shown to have done any
■act contrary to law, that no prima facie case of unlawful combina-
tion or criminal conspiracy has been shown by the testimony, they
are hereby discharged.
COTE V. MURPHY.
Supreme Court of Pennsylvania, 1894.
159 Pennsylvania, 420.
Opinion by Mr. Justice Dean, January 2, 1894 : '
The defendants were members of the Planing Mill Associa-
tion of Allegheny county, and Builders' Exchange of Pittsburgh.
The different partnerships and individuals, composing these associa-
tions, were in the business of contracting and building and furnish-
ing building material of all kinds. On the ist of May, 1891,
there was a strike of the carpenters, masons and bricklayers in
the building trades, bringing about, to a large extent, a stoppage
of building.
The men demanded an eight hour day, with no reduction in
wages theretofore paid, which the employers refused to grant;
then a strike by the unions of the different trades was declared.
The plaintiff, at the time, was doing business in the city of Pitts-
burgh as a dealer in building materials. He was not a member of
' The opinion only is printed.
368 Cases on Criminal Law.
either the "Planing Mill Association," or of the "Builders' Ex-
change ; " there were also contractors and builders, who belonged
to neither of these organizations, who conceded the demands of the
workmen ; they sought to secure building material from dealers
wherever they could, and thus go on with their contracts ; if they
succeeded in purchasing the necessary material, the result would
be, that at least some of the striking workmen would have em-
ployment at a higher rate of wages than the two associations were
willing to pay ; the tendency of this was to strengthen the cause of the
strikers, for those employed were able to contribute to the support
of their fellow workmen who were idle. The two associations
already named, sought to enlist all concerned as contractors and
builders or as dealers in supplies, whether members of the associa-
tions or not, in the furtherance of the one object, resistance to the
demands of the workmen. The plaintiff, and six other individuals
or firms engaged in the same business, refused to join them, and
undertook to continue sales of building material to those builders
who had conceded the eight hour day. The Planing Mill Associa-
tion and Builders' Exchange tried to limit their ability to carry on
work at the advance, by inducing lumber dealers and others to re-
frain from shipping, or selling them in quantities, the lumber and
other material necessary to carrying on the retail business ; in sev-
eral instances, their efforts were successful, and the plaintiff did not
succeed in purchasing lumber from certain of the wholesale dealers
in Cleveland and Dubois, where he wanted to buy. The defend-
ants were active members of one or other or both of the associa-
tions engaged in the contest with the striking workmen. The
strike continued about two months ; after it was at an end, the
plaintiff brought suit against defendants, averring an unlawful and
successful conspiracy to injure him in his business, and to interfere
with the course of trade generally, to the injury of the public ; that
the conspiracy was carried out by a refusal to sell to him building
materials themselves, and by threats and intimidation preventing other
dealers from doing so. Under the instructions of the court upon the
evidence, there was a verdict for plaintiff in the sum of ^2,500
damages, which the court reduced to ;g 1,500 ; then judgment, and
from that defendants take this appeal.
The plaintiffs case is not one which appeals very strongly to
a sense of justice. The mechanics of Pittsburgh, engaged in the
Cases on Criminal Law. 369
different building trades, on ist of May, 1891, demanded that
eight hours should be computed as a day in payment of their
wages. Their right to do this is ckar. It is one of the indefeasi-
ble rights of a mechanic or laborer in this commonwealth to fix
such value on his services as he sees proper, and, under the consti-
tution, there is no power lodged anywhere to compel him to work
for less than he chooses to accept. But in this case the workmen
went further ; they agreed that no one of them would work for less
than the demand, and by all lawful means, such as reasoning and
persuasion, they would prevent other workmen from working for
less. Their right to do this is also clear. At common law, this
last was a conspiracy and indictable, but under the acts of 1869,
1872, 1876 and 1 89 1, employees, acting together by agreement,
may, with few exceptions, lawfully do all those things which the
common law declared a conspiracy. They are still forbidden, in
the prosecution of a strike, preventing any one of their number
who may desire to labor from doing so, by force or menace of
harm to person or property ; but the strike here was conducted
throughout in an orderly, lawful manner. The employers, con-
tractors and others, engaged in building and furnishing supplies,
members of the two associations already mentioned, to which
these defendants belonged, refused to concede the demands of the
workmen, and there then followed a prolonged and bitter contest.
The members of the associations refused to furnish supplies to
those engaged in the construction of any building where the con-
tractor had conceded the eight hour day. This, as individual deal-
ers, they had a clear right to do. They could sell and deliver their
material to whom they pleased. But they also went further ; they
agreed among themselves that no member of the association would
furnish supplies to those who were in favor of or had conceded the
eight hour day, and that they would dissuade other dealers, not
members of the associations, from furnishing building material to
such contractors or retail dealers ; to the extent of their power,
this agreement was carried out. This clearly was combination,
and the acts of assembly referred to do not, in terms, embrace
employers; they only include within their express terms Workmen ;
hence, it is argued by counsel for appellee, these defendants are
subject to all the common law liability of conspirators in their
attempts to resist the demand for increased wages ; that is, there
370 Cases on Criminal Law.
can be a combination among workmen to advance wages, but there
can be no such combination of employers to resist the advance ;
that which by statute is permitted to the one side, the common law
still denies to the other. If this position be well taken, we then
have this inequality ; the plaintiff who is aiding a combination,
either directly or indirectly, intentionally or unintentionally, to
advance wages, sues for damages members of another combination
who resist the advance. Nor is there any difference in the char-
acter of the acts or means on both sides in furtherance of their
purposes. The workmen will not work themselves, and they use
persuasion and reason with their fellows to keep them from going
to work until the demand is conceded ; the employers will not sell
to contractors who concede the demand, and they do their best to
persuade others engaged in the same business from doing so.
Then, the element of real damage to plaintiff is absent ; by
far the larger number of dealers in the city and county were mem-
bers of the combination which refused to sell ; only the plaintiff
and six others refused to enter the combination ; the result was
that these seven had almost a monopoly of furnishing supplies to
all builders who conceded the advance. Plaintiff admits in his own
testimony that thereby his business and profits largely increased ;
in a few instances he paid more to wholesale dealers and put in
more time buying than he would have done if the associations had
not interfered with those who sold him ; but it is not denied that,
as a result of the combination, he was individually a large gainer.
True, he avers that, if defendants had gone no further than to re-
fuse to sell themselves, he would have made a great deal more
money; that is, he did not make as large a sum as he would
have made if they had not dissuaded others, not members of the
association, from seUing to him; but that, by the fact of the
combination and strike, he was richer at the end than when they
commenced, is not questioned.
We have then these facts, somewhat pecuHar in the adminis-
tration of justice: A plaintiff suing and recovering damages for an
alleged unlawful act, of which he himself, in so far as he aided the
workmen's combination, is also guilty, and both acts springing
from the same source, a contest between employers and employed
as to the price of daily wages ; and then the further fact, that this
contest, instead of damaging him, resulted largely to his profit.
Gases on Criminal Law. 371
We assume, so far as concerns defendants, if their agreement
was unlawful, or if lawful, it was carried out by unlawful acts to the
damage of plaintiff, the judgment should stand. All the authori-
ties of this state go to show that while the act of an individual may
not be unlawful, yet the same act, when committed by a combina-
tion of two or more, may be unlawful, and therefore be actionable.
A dictum of Lord Denman, in R. v. Seward, i A. & E, 711,
gives this definition of a conspiracy : " It is either a combination to
procure an unlawful object, or to procure a lawful object by unlaw-
ful means." This leaves still undetermined the meaning to be
given the words lawful and unlawful, in their connection in the
antithesis. An agreement may be unlawful in the sense that the
law will not aid in its enforcement, or recognize it as binding upon
those who have made it, yet not unlawful in the sense that it will
punish those who are parties to it, either criminally or by a verdict
in damages. Lord Denman is reported to have said afterwards in
R. V. Heck, 9 A. & E. 690, that his definition was not very cor-
rect. See note to sec. 2291, Wharton's Criminal Law.
It is conceded, however, in the case in hand, any one of defend-
ants, acting for himself, had a right to refuse to sell to those favor-
ing the eight hour day, and so, acting for himself, had the right to
dissuade others from selling. If the act were unlawful at all, it
was because of the combination of a number. Gibson, J., in Com.
V. Carhsle, Brightly's R. 39 says : " Where the act is lawful for
the individual, it can be the subject of conspiracy when done in
concert, only where there is a direct intention that injury shall
result from it, or where the object is to benefit the conspirators to
the prejudice of the public or the oppression of individuals, and
where such prejudice or oppression is the natural and necessary
consequence."
In the same case it is held : " A combination is criminal,
wherever the act to be done has a necessary tendency to prejudice
the public, or to oppress individuals by unjustly subjecting them to
the power of the confederacy, and giving effect to the purposes of
the latter, whether of extortion or mischief, According to this
view of the law, a combination of employers to depress the wages
of journeymen below what they would be if there was no re-
currence to artificial means on either side, is criminal." This case
puts the law against the combination in as strong terms, if not
,37:2 Cases ON Criminal Law.
stronger, than any others of our own state. The significant qualifi-
cation of the general principle, as mentioned in the last three lines,
will be noticed, "if there was no recurrence to artificial means, on
either side." The prejudice to the public is the use of artificial
means to affect prices whereby the public suffers. A combination
of stock brokers to corner a stock, of farmers to raise the price pf
grain, of manufacturers to raise the price of their product, of em-
ployers to reduce the price. of labor, of workmen to raise the price,
were at the date of that decision, at common law, all conspiracies.^
The fixed theory of courts and legislators then was, that the price
of everything ought to be, and in the absence of combination
necessarily would be, regulated by supply and demand. The first
to deny the justice of this theory, and to break away from it, was
•labor, and this was soon followed by the legislation already noticed,
relieving workmen from the penalties of what, for more than a cen-
tury, had been declared unlawful .combinations or conspiracies
Wages^ it was argued, should be fixed by the fair proportion labor
had contributed in production ; the market price, determined by
supply and demand, might or might not be fair wages, often was
not, and as long as workmen were not free by combination to
insist on their right to fair wages, oppression by capital, or which is
the same thing, by their employers, followed. It is not our busi-
ness to pass on the soundness of the theories which prompt the
enactment of statutes. One thing, however, is clear ; the moment
the legislature relieved one and by far the larger number of the cit-
izens, of the commonwealth from the common law prohibitions
against combinations to raise the price of labor and by a combina-
tion the price was raised, down went the foundation on which com-
mon law conspiracy was based, as to that particular subject. Before
"any legislation on the question, it was held that a combination of
workmen to raise the price of labor, or of employers to depress it,
was unlawful, because such combination interfered with the price
which would otherwise be regulated by supply and , demand; this
interference was in restraint of trade or business, and prejudicial to
, the public at large. Such combination made an artificial price ;
workmen, by reason of the combination, were not willing to work
''■Contra : Combinations to niaintainrates of insurance. JEXaa. Ins. Co,
, J/., C, SI S. W. (Ky.), 624(1899) Ed. .J; , - ; ,
Gases on Criminal Law. 373
for what otherwise they would actept ; employers would not pay
what otherwise they would consider fair wages. Supply and de-
mand consist in the atnount of labor for sale and the needs of the
employer who buys. If more men offer to sell labor than are
needed, the price goes down and the employer buys cheap ; if
fewer than required offer, the price goes up and he buys dear ;
as every seller and buyer is free to bargain for himself, the price
is regulated solely by supply and demand. On this reasoning was
founded common law conspiracy in this class of cases. But, in
this case, the workmen, without regard to the supply of labor or the
demand for it, agree upon what in their judgment is a fair price,
and then combine in a demand for payment of that price ; when
refused, in pursuance of the combination, they quit work, and
agree not to work until the demand is conceded ; further they '■
agree by lawful means to prevent all others, not members of the
combination,. from going to work until the employers agree to pay
the price fixed by the combination. And this, as long as no force
was used, or menaces to person or property, they had a lawful ■
right to do. And so far as is known to us, the price demanded
by them may have been a fair one. But it is nonsense to say that
this was a price fixed by supply and demand ; it was fixed by a
combination of workmen on their combined judgment as to its
fairness ; and, that the supply might not lessen it, they combined
to prevent all other workmen in the market from accepting less.'
Then followed the combination of employers, not to lower the
wages theretofore paid, but to resist the demand of a combination
for an advance ; not to resist an advance which- would naturally
follow a limited supply in the market, for the supply, so far as the
workmen belonging to the combination was concerned, was by
combination wholly withdrawn, and as to workmen other than
members, to the extent of their pOwer, they kept them out of the
market ; by artificial means the market supply was almost wholly
cut off. The combination of the employers, then, was nottointer-
fere with the price of labor as determined by the conimon law
theory, but to defend themselves against a demand made alto-
gether regardless of the price as regulated by the supply. The
element of an unlawful combination to restrain trade because, df
greed of profit to themselves, or of mahce toward plaintiff or
others is lacking, and this is the essential element on which are
374 Cases on Criminal Law.
founded all decisions as to common law conspiracy in this class of
cases. And however unchanged may be the law as to combina-
tions of employers to interfere with wages, where such combina-
tions take the initiative, they certainly do not depress the market
price when they combine to resist a combination to artificially ad-
vance price.
"The reason of the law is the life of the law," and, as given
in the cases cited by appellee, irresistibly impels to the conclu-
sion that the combination here was not unlawful ; a conclusion
which is clearly indicated in Com. v. Carlisle, supra, that it would
not be unlawful, if there was first recurrence to artificial means by
workmen to raise the market price. Here, the first step provoca-
tive of a combination by the employers, was an attempt by lawful,
artificial means on part of the workmen to control the supply
of labor, preparatory to a demand for an advance.
Nor does the fact that the appellee was not a workman or a
member of any of the unions of workmen, put him in any better
attitude than if he were. He undertook for his own profit to aid
the cause of the workmen ; his right to do so was unquestionable.
But, if the employers by a lawful combination could limit his abil-
ity so to do, they did not make themselves answerable in damages
to him for the consequences of a lawful act.
The case of Morris Run Coal Co. v. Barclay Coal Co., 68 Pa.
173, is not in point; it was the attempt to enforce the collection
of a draft, given by one member of a combination, formed to raise
the price of coal, to another, in consideration of certain stipulations
in the agreement. It was held that the combination, being in
restraint of trade, was unlawful, and, as the draft was given in
pursuance of the unlawful contract, it also was tainted with the
illegality, and there could be no recovery.
But, if the agreement itself were not unlawful, were the
methods to carry it out unlawful? If the employers' combination
here had used illegal methods or means to prevent other dealers
from selling supplies to plaintiff, the conspiracy might still have
been, found to exist. The threats referred to, although what are
usually termed threats, were not so in a legal sense. To have said
they would inflict bodily harm on other dealers, or villify them in
the newspapers or bring on them social ostracism, or similar declara-
tions, these the law would have deemed threats, for they may deter
Cases on Criminal Law. 375
a man of ordinary courage from the prosecution of his business in
a way which accords with his own notions ; but to say, and even
that is inferential from the correspondence, that if they continued
to sell to plaintiff the members of the association would not buy
from them, is not a threat. It does not interfere with the dealer's
free choice ; it may have prompted him to a somewhat sordid cal-
culation ; he may have considered which custom was most profit-
able, and have acted accordingly ; but this was not such coercion
and threats as constituted the acts of the combination unlawful :
Rodgers z/. Duff, 13 Moore, P. C. 209; Bowen v. Matheson, 14
Allen, 499 ; Bohn Manufacturing Co. v. Hollis, et al.. Supreme
Court of Minnesota, manuscript opinion, not yet reported [55 N.
W. R. 1 119].
On the main question, the case last cited goes further than
we are called upon to go, as yet, in this state. It holds that what
is not unlawful when done by an individual cannot be unlawful
when done by many, and therefore the combination not to deal
with those who broke the rules of the association was not a con-
spiracy. For this, a number of cases from other states as well as
from England are cited. But the law in this state has heretofore
been determined otherwise from a very early day by an unbroken
line of decisions which here call for no qualification ; for, so far as
concerns the facts of this case, the legislature has so changed 'the
law as to render these decisions inapplicable. We concede, how-
ever, that the decisions of other courts are by no means uniform.
Mr. Wright, in his work on the Law of Criminal Conspiracies and
Agreements (London, 1873), says : " It is conceived, that, on a re-
view of all the decisions, there is a great preponderance of authority
in favor of the proposition that, as a rule, an agreement or com-
bination is not criminal, unless it be for acts or omissions, whether
as ends or means, which would be criminal apart from agreement"
Logically, the same rule would apply, as was held in Bohn
Manufacturing Co. v. Hollis, to combinations which, although not
criminal, are alleged to be unlawful.
But without regard to whether the general rule be settled
by the weight of authority, as claimed by the appellants, we hold
here that this combination was not unlawful, because: i. It was
not made to lower the price of wages as regulated by the supply
and demand, but to resist an artificial price made by a combination
376 Cases on Criminal Law.
which by statute was not unlawful. 2. The methods adopted to
further the objects of the combination were not unlawful.
Another point has been most earnestly pressed upon our
consideration by counsel for appellants. It is argued that, under
our declaration of rights, either the acts of assembly of 1869, 1872,
1876 and 1891, exempting employees from the penalties of unlaw-
ful combination to fix the price of labor are void, because, by their
terms, they embrace only a particular class of citizens of the com-
monwealth, or their scope must be enlarged beyond the express
terms of these acts so as to include within their protection all those
interested in the same subject of legislation. It is argued that it is
not within the power of the legislature to declare some citizens
innocent of any offence against the law, for the very same act,
which, when committed by some others in the same business, the
law will still hold to be criminal ; that what the statute declares is
not conspiracy in one case cannot, under the law, be conspiracy in
the other ; and therefore in every contest of this kind between
workmen and employers, the statute, if not void, must, at least,
be held to operate equally to the exemption of all citizens inter-
ested in the subject affected by the combination ; if there be noth-
irig criminal in a combination to artificially raise wages, there can
be nothing criminal in an employers' combination tO' resist the ad-
vance or to artificially depress them.
This question is not in the case, in the view we have taken of
the facts. We are at all times averse to passing on questions the
answers to which are not necessary to a decision of the case im-
mediately before us, much less are we inclined to discuss and
decide questions involving the constitutional power of a co-ordi-
nate branch of the government. For this reason we refrain from
a; consideration of the able argument of counsel for appellant on
this point.
The refusal of the court below to affirm appellant's seventh
prayer for instructions, that, " Under all the evidence the verdict
must be for defendants," was error, and, being here assigned for
error, the appeal is sustained and judgment reversed.
Cases on Criminal Law. 377
STATE V. STEWART.
Supreme Court of Vermont, 1887.
59 Vermont, 273.
Indictment for a conspiracy to hinder and prevent the Ryegate
Granite Works, a corporation doing business at Ryegate, from
employing certain granite cutters, and for hindering and deterring
certain laborers from working for the said corporation. Heard,
June Term, 1885, Ross, J., presiding, upon respondents' demurrer
and motion to quash the indictment. The demurrer was overruled
pro forma, and the motion to quash denied ; to which the respond-
ents e^tcepted.^
The opinion of the court was delivered by
Powers, J. Although authorities can be found that lay down
the rule that felonies and misdemeanors, or different felonies, can-
not be joined in the same indictment, still the rule in this and
most of the states is otherwise.
It is always and everywhere permissible for the pleader to set
forth the offense he seeks to prosecute in all the various ways
necessary to meet the possible phases of evidence that may appear
at the trial. If the counts cover the same transaction, though
involving offenses of different grade, the court has it in its power to
preserve all rights of defense intact. Commonwealth v. McLaugh-
lin, 12 Cush., 612; State v. Lincoln, 49 N. H., 464; State v.
Shialley, 50 Vt., 736 ; State v. Thornton, 56 Vt., 35 ; Rex v. Fer-
guson, 2 Stark, 489. Moreover, the inotion to quash is addressed
to the discretion of the court, and its refusal is not the subject of
revision here. Commonwealth v. Eastman, i Cush., 189; Com-
monwealth V. Ryan, 9 Gray, 137 ; i Wharton Cr. Law, s. 519.
The respondents' counsel argues that the first and second
counts do not cover the offense of criminal conspiracy at common
kw. But we think upon a careful examination of the English and
American cases cited in argument, and we suspect that none have
been overlooked on either side, that it is clear to a demonstration
that a combination of the character set forth in these counts was a
conspiracy at the common law; and, further, that the subject-
^ The indictment and arguments of counsel are omitted.
378 Cases on Criminal Law.
matter of the offense being the same in this country as in England ;
namely, an interference with the property rights of third persons,
and a restraint upon the lawful prosecution of their industries as
well as an unlawful control over the free use and employment by
workmen of their own personal skill and labor, at such times, for
such prices, and for such persons as they please, the common law
of England is " applicable to our local situation and circumstances "
in this behalf, and is therefore the common law of Vermont.
In England and here it is lawful and, it may be added, com-
mendable for any body of men to associate themselves together for
the purpose of bettering their condition in any respect, financial or
social. The very genius of free institutions invites them to higher
levels and better fortunes. They may dictate their own wages,
fraternize with their own associates, choose their own employers,
and serve man and mammon according to the dictates of their own
conscience.
But while the law accords this liberty to one, it accords a like
liberty to every other one ; and all are bound to so use and enjoy
their own liberties and privileges as not to interfere with those of
their neighbors.
All the legislation in England and America has been pro-
gressively in the direction of according to laborers the enjoyment
of equal rights with others.
The early English statutes, beginning with the middle of the
fourteenth century, are to be read in the light of the civilization of
that day, and their provisions, to us of the nineteenth century,
harsh, illiberal and tyrannical, were but the reflex of the prevalent
notions of class distinctions that shaped and guided the social and
political polity of those days.
From time to time, however, down to 1875, this legislation
has been liberalized and christianized ; and to-day in England, as
here, workmen stand upon the same broad level of equality before
the law with all other vocations, professions, or callings whatsoever,
respecting the disposition of their labor and the advancement of
their associated interests.
There, as here, it is unlawful for employers wrongfully to
coerce, intimidate or hinder the free choice of workmen in the dis-
posal of their time and talents. There, as here, it is unlawful for
workmen wrongfully to coerce, intimidate or hinder employers in
Cases on Criminal Law. 3 79
the selection of such workmen as they choose to employ. There,
as here, no employer can say to a workman he must not work for
another employer, nor can a workman say to an employer he can-
not employ the service of another workman.
By the law of the land, these respondents have the most
unquahfied right to work for whom they please, and at such prices
as they please. By the law of the land, O' Rourke and Goodfellow
have the same right. By the same law, the Ryegate Granite Com-
pany has the right to employ the respondents or O'Rourke on such
terms as may be mutually agreed upon, without let, hinderance or
dictation from any man or body of men whatever.
Suppose the members of a Bar Association in Caledonia
County should combine and declare that the respondents should
employ no attorney, not a member of such association, to assist
them in their defense in this case, under the penalty of being
dubbed a "scab," and having his name paraded in the public press
as unworthy of recognition among his brethren, and himself brought
into hatred, envy and contempt, would the respondents look upon
this as an innocent intermeddling with their rights under the law ?
The proposition has only to be stated to disclose its utter incon-
sistency with every principle of justice that permeates the law
under which we live.
If such conspiracies are to be tolerated as innocent, then every
farmer in Vermont, now resting in the confidence that he may
employ such assistance in carrying on his farm as he thinks he can
afford to hire, is exposed to the operation of some secret code of
law, in the framing of which he had no voice, and upon the terms
of which he has no veto, and every manufacturer is handicapped
by a system that portends certain destruction to his industry. If
our agricultural and manufacturing industries are sleeping upon
the fires of a volcano, liable to eruption at any moment, it is high
time our people knew it.
But happily such is not the law, and among English-speaking
people never has been the law. The reports, English and Amer-
ican, are full of illustrations of the doctrine that a combination of
two or more persons to effect an illegal purpose, either by legal or
illegal means, whether such purpose be illegal at common law or
by statute ; or to effect a legal purpose by illegal means, whether
such means be illegal at common law or by statute, is a common
380 Cases on Criminal Law. '
law conspiracy. Such combinations are equally illegal whether
they promote objects or adopt means that are per se indictable ; or
promote objects or adopt means that are per se oppressive, immoral
or wrongfully prejudicial to the rights of others.
If they seek to restrain trade, or tend to the destruction of
the material prosperity of the country, they work injury to the
whole public.
These propositions are the clear deduction of the cases cited
in argument, and breathe a spirit of equality and justice that must
commend itself to every intelligent mind.
Counsel have cited to us no case in which it has been ruled
that this crime of conspiracy does not exist at the common law.
We are referred to Mr. Wright's clever monograph upon Crim-
inal Conspiracies, wherein the author, though not denying that
conspiracies to injure industries and against the free exercise of
one's calling according to his own choice, were held to be criminal
at the common law, still attempts to throw doubt upon the basis
upon which the doctrine rests.
But when in i Hawkins' Pleas of the Crown, c. 27, s. 2 (a book
of- great authority), 2 Russell on Crimes, 674, it is laid down "that
all conspiracies whatever, wrongfully to prejudice a third person,
are highly criminal at common law ; " and in 2 Wharton's Crim-
inal Law, s. 2322, it is said that "a combination is a conspiracy in
law whenever the act to be done has a necessary tendency to pre-
judice the public or oppress individuals, by unjustly subjecting
them to the power of the confederates, and giving effect to the
purposes of the latter, whether of extortion or mischief;" and the
same proposition, in one form of expression and another, is laid
down- in 2 Bishop's Criminal Law, s. 172 ; and in Desty-'s Criminal
Law, s. II ; and in 3 Chitty's Criminal Law, 1138 ; and in Arch-
bold's Crim. Prac. & PI. 1830; and it was said by Denman, Ch. J.,
in Queen v. Kenrick, 5 Q. B., 49 : " It was contended, in the first
place, that the third count was bad. by reason of uncertainty, as
giving no notice of the offense charged. The whole law of con-
spiracy.as it has been administered at least for the last hundred years,
has been thus called in question ; for we have sufficient proof that
during that period any combination to prejudice another unlaw-
fully has been considered as constituting the offense so called.
The offense has been held to consist in the conspiracy, and not in
Cases on Criminal Law. 381
the acts committed for carrying it into effect ; and the charge has
been held to be sufficiently made in general terms describing an
unlawful conspiracy to effect a bad purpose ; " and Baron Rolfe,
in Reg. v. Selby, 5 Cox Crim. Cas. 495 ; and Tindal, Ch. J., in
Reg. V. Harris, i Car. & Marsh. 661 ; and Crompton, J., in Hilton
V. Eckersley, 6 E. & B. 47 ; and Grove, J., in Rex v. Mawbey, 6
T. R. 619; and Lord Mansfield, in Rex ?/. Eccles, i Leach
Crown, Cas. 274 ; and Hill, J., in Walsby v. Anley, 3 E. & E. 5 16 ;
and Campbell, Ch. J., in Reg. v. Rowlands, 17 Adolp. & El.
670 ; and Baron Bramwell, in Reg. v. Druitt, 10 Cox Crim. Cas.
592; and Brett, J., in Reg. v. Bunn, 12 Cox Crim. Cas. 316;
and Malins, V. C, in Springhead Co. v. Riley, L. R. 6 Eq. 551 ;
and Coleridge, Ch. J., in Mogul S. S. Co., v. McGregor, L. R. 15
Q. B. Div. 476; and Shaw, Ch. J., in Commonwealth v. Hunt, 4
Met. Ill, 128; and Caton, Ch. J., in Smith v. The People, 25 111.
17 ; and Gibson, Ch. J., in Commonwealth v. Carlisle, Journal
Jurisprudence, 225; and Chapman, Ch. J., in Carew v. Rlitherford,
106 Mass. I, — have all added their endorsement of the doctrine
advanced as early as the work of Hawkins, supra; it is mani-
fest that we are compelled to forsake the literature of doubt, and
' to cleave unto that of authority. See also Rex v.. Ferguson, 2
, Starkie, N. P. 489; Rex v. Bykerdyke, i M. & Rob. 179;
People z'. Fisher, 14 Wend. 9 ; State v. Donaldson, 3 Vroom, 32,
N. J. L., 151 ; Snow v. Wheeler, 113 Mass. 186; State v. Noyes,
25 Vt. 415 ; State v. Burnham, 15 N. H. 396 ; Morris Run Coal
Co. V. Barclay Coal Co. 68 Penn. St. 173.
Vice-Chancellor Malins, in the case cited, supra, states the law
of the subject in brief but intelligible words: "Every man is at
liberty to enter into a combination to keep up the price of wages ;
but if he enteis into a combination for the object of. interfering
with the perfect freedom of action of another man, it is an offense,
not only at common law, but under Act 6, Geo. 4, c. 129."
The principle upon which the cases, English and American,
proceed, is, that every man has the right to employ his talents,
industry and capital as he pleases, free from the dictation of
others ; and if two or more persons combine to coerce his choice
,in this behalf, it is a criminal conspiracy. The labor and skill of
the workman, be it of high or low degree, the plant of the manu-
facturer, the equipment of the farmer, the investments of com-
382 Cases on Criminal Law.
merce, are all in equal sense property. If men by overt acts of
violence destroy either, they are guilty of crime. The anathemas
of a secret organization of men combined for the purpose of
controlling the industry of others by a species of intimidation that
works upon the mind rather than the body, are quite as danger-
ous, and generally altogether more effective, than acts of actual
violence. And while such conspiracies may give to the individual
directly affected by them a private right of action for damages,
they at the same time lay a basis for an indictment on the ground
that the State itself is directly concerned in the promotion of all
legitimate industries and the development of all its resources, and
owes the duty of protection to its citizens engaged in the exercise
of their callings. The good order, peace and general prosperity
of the State are directly involved in the question.
In the case at bar, the third and fourth counts set forth more
particularly the methods adopted by the respondents to interfere
with the prosecution of its business by the Ryegate Granite
Works. They charge the respondents with an intent to pre-
vent the prosecution of the work of that company by threaten-
ing O'Rouke, Goodfellow and others, that the Ryegate Granite
Works were "scab shops" and all workmen therein were "scabs"
and their names would be published in the " scab " list in the
Granite Cutter's Journal, and that they would be shunned and not
allowed to work with any other granite cutters, and would be dis-
graced in the craft, etc.; by all of which O'Rourke, Goodfellow
and others were frightened and driven away from said shops.
The exposure of a legitimate business to the control of an
association that can order away its employees and frighten away
others that it may seek to employ, and thus be compelled to cease
the further prosecution of its work, is a condition of things utterly
at war with every principle of justice and every safeguard of pro-
tection that citizens under our system of government are entitled
to enjoy. The direct tendency of such intimidation is to establish
over labor and over all industries, a control that is unknown to
the law, and that is exerted by a secret association of conspirators,
that is actuated solely by personal considerations, and whose plans,
carried into execution, usually result in violence and the destruction
of property.
That evils exist in the relations of capital and labor, and that
Cases on Criminal Law. 383
workmen have grievances that oftentimes call for relief, are facts
that observing men cannot deny. With such questions, we, as a
court, have no function to discharge further than to say that the
remedy cannot be found in the boycott.
We do not deem it necessary to extend this discussion—
already too long drawn out — in following seriatim the numerous
objections taken in the able and elaborate brief of the respondents
to the different counts of this indictment. The general scope of
the views expressed covers the whole ground, we think ; and the
result is, the judgment of the County Court overruling the
motion to quash and overruling the demurrer, and adjudging the
indictment to be sufficient, is affirmed; and the cause is remanded,
to be further proceeded with.'
SHANNON V. COMMONWEALTH.
Supreme Court of Pennsylvania, 1850.
14 Pennsylvania, 226.
The opinion of the court was delivered, October 9th by
Gibson, C. J.^ Of the impolicy of holding a tight rein over
the doctrine of conspiracy, I expressed my opinion in Mifflin v.
The Commonwealth, 5 W. & Sen 464, without intending to inti-
mate that it should be suffered to run wild. It ought, at least, to
appear that not only the end to be accomplished, but the motive
for it was wicked. In every count of this indictment the combina-
tion is laid to be an agreement to commit adultery, without refer-
ence to time, place, or circumstance. The sum of the charge
is joint consent, which is an ingredient in every fornication or
adultery ; and if it were separately a substantive offence, parties
acquitted of actual connection, might be put on trial for what
would be, in morals, a lower degree of the same transgression.
The statute which made it a temporal offence, contains no provi-
sion for splitting it into degrees, like homicide, to give the prose-
"^ Accord: Boycotting, St. v. Glidden, 55 Conn., 46 (1887); Crump v. C,
84 Va., 927 (1888).— Ed.
2 The opinion only is printed.
, 3?4 Cases ON Criminal Law.
cution of it more than a single chance of success. If consent to
an adultery be a lower degree of temporal crime, why might not
the parties to it be found guilty of it on an indictment for actual
connection ? Because, it may be said, confederacy is an offence
of a different stamp. It is so in form, but not in substance, else
an adultery or a fornication consummated, would consist of dis-
tinct and different crimes. But to call the thing by different
names would not enable the attorney-general to put the parties
twice in jeopardy for it. If confederacy constituted conspiracy,
without regard to the quality of the act to be done, a party
might incur the guilt of it by having agreed Xo be the passive
subject of a battery, which did not involve him in a breach of the
peace. By such preconcerted encounters, it has been said, a
reputation for prowess is sometimes purchased by gentlemen of
the fancy. In the same way there might be a conspiracy to com-
mit suicide by drowning or hanging in concert, according to the
method of the Parisian roues, though no one could be indicted
of the felony if it were committed. . It may be said such con-
spiracies are ridiculous and improbable. But nothing is more
ridiculous than a conspiracy to commit adultery — were we not
bound to treat it with becoming gravity, it might provoke a smile —
or more improbable than that the parties would deliberately post-
pone an opportunity to appease the most unruly of their appetites.
These are subtile premises for a legal conclusion ; but their
^ubtilty is in the analysis of the principle, not in the manner of
treating it. .
It is impossible to lay down a rule for all cases ; but it may be
, said that where concert is a constituent part of the act to be done,
as it is in forpication and adultery, a party acquitted of the major
cannot be indicted of the minor. If.it were an integral offence,
and not an integral part of one, he might otherwise be convicted
of it, though he had been before convicted of the whole. We
understand that this plaintiff in error had been acquitted of actual
^adultery ; and though the fact is not found in the record, it shows
how readily an indictment for the substance of the same thing in
another form might be made a means of oppression.
When an adulterous enterprise has been relinquished — and it
ought, like every other criminal design, to have its locus penifentia,
— it is impossible to believe that society has bee^i' so scathed by it,
Cases on Criminal Law. 385
as to admit of no propitiation for it but public castigation. It
has been said by unerring wisdom, that if a man look upon a
woman to lust after her, he hath committed adultery with her
already ; but God alone may judge the offences of the heart. Its
lust is not the adultery which the statute has bared to the tem-
poral lash. The framers of it knew the futility of attempting to
smother the instincts of our nature, or to cleanse our thoughts by
an Act of Assembly. Legislation can do no more than protect the
public or an individual from overt acts; but how a design, aban-'
doned or suppressed, could be injurious to either, has not been
disclosed. Doubtless a confederacy to dishonor a man and disgrace
his family, by debauching his wife, would be indictable at the out-
set ; but it would be more guilty in its object and mischievous in
its consequences than the appointment for the indulgence of a pas-
sion or the gratification of a desire. Besides, the danger from the
uncertainty of the evidence would be imminent. The purest inti-
macy is sometimes mistaken for an intrigue, which is always a
mystery ; and the reputation of many a virtuous wife is sacrificed
to the insinuations of an enemy, working on the credulity of a sus-
picious husband. Would it mend the matter much, to make the
grounds of such suspicions a subject of public investigation?
Decency and justice require that such investigations be not
encouraged. Judgment reversed}
PEOPLE V. MATHER.
Supreme Court of New York, 1830.
4 Wendell, 229.
Marcy, J.'' It is contended that the judge erred in instruct-
ing the jury that to convict the defendant they must be satisfied
that he was a party to the conspiracy at its formation originally,
and that his rendering assistance in carrying it into execution, after
it was formed, would not make him a party to it.
1 Accord: Miller i/. St., 58 Ala. 390 (1877) ; compare St. v, Huegin,
8s N. W. (Wis.) 1046 (1901).— Ed.
2 Part of this case is omitted.
386 Cases on Criminal Law.
The proof established a conspiracy in or about Canandaigua to
take Morgan from the jail at that place and to carry him away.
There was no evidence to show that the defendant was then a party
to it. His first visible connection with those who commenced the
illegal act, if he was at all connected with them, was after Morgan
had been removed seventy miles from Canandaigua.
The language of the charge warrants the belief that the judge
thought there was but one conspiracy proved. There is no propo-
sition better established than that the venue in a criminal case must
be laid in the county where the offence was committed. In indict-
ments for conspiracy the venue may be laid in any county in which
it can be proved that an overt act was done by any one of the con-
spirators in furtherance of their common design (Archb. Crim. P. 6).
Where a conspiracy was formed at sea, and an overt act done in the
county of Middlesex, it was held that the venue was properly laid
in that county (The King v Bresac & Scott, 4 East, 164). So in
the case of The King v. Bowes and others, referred to in The King
V. Bresac & Scott, the conspirators were tried in Middlesex, though
there was no proof of an actual conspiracy within that county, and
the acts and doings of some of them were wholly in other counties.
All these cases must proceed, I think, on the principle that the
crime is committed where the overt act is performed. I admit that
it is the illegal agreement that constitutes the crime, when that is
concluded the crime is perfect, and the conspirators may be con-
victed if the crime can be proved. No overt act need be shown or
even performed to authorize a conviction. If conspirators enter into
the illegal agreement in one county; the crime is perpetrated there,
and they may be immediately prosecuted ; but the proceedings
against them must be in that county. If they go into another
county to execute their plans of mischief, and there commit an overt
act, they may be punished in the latter county without any evi-
dence of an express renewal of their agreement. The law consid-
ers that wherever they act there they renew, or perhaps to speak
more properly, they continue their agreement, and this agreement
is renewed or continued as to all whenever any one of them does
an act in furtherance of their common design. In this respect con-
spiracy resembles treason in England when directed against the life
of the king. The crime consists in imagining the death of the king.
In contemplation of law the crime is committed wherever the traitor
Cases on Criminal Law. 387
is, and furnishes proof of his wicked intention by the exhibition of
any overt act.
If the proposition which I have stated relative to conspirators
be correct (^and there is no accounting for the decisions on this sub-
ject unless it be upon the principle I have mentioned), it necessar-
ily follows that whenever a new party concurs in the plans originally
formed, and comes in to aid in the execution of them, he is from
that moment a fellow conspirator. He commits the offence when-
ever he agrees to become a party to the transaction or does any act
in furtherance of the original design.
If this conclusion is properly deduced from the authorities re-
ferred to, the judge erred in saying to the jury that although it
should satisfactorily appear that the defendant assisted in carrying
the conspiracy into execution after its formation, that fact would
not make him a party to it. This doctrine of the judge would seem
to render it impossible for a new party to be added to the original
conspirators. Can it be true that if two men conspire to commit a
criminal act and afterwards twenty others co-operate with them in
executing the plan these last are not conspirators ? If a series of
acts are to be performed with a view to produce a particular result
he who aids in the performance of any one of these acts in order to
bring about the result must have the intention to effectuate the end
proposed, and if he operates with others, knowing them to have the
same design, there is in fact an agreement between him and them ;
his criminal intent is not to be distinguished from the intent of those
who first formed the plans of the conspiracy. If two-thirds of the
journeymen of any particular mechanic art in a city should agree
to turn out for higher wages, and after the agreement was formed
the other third should join them, would those who last acceded to
the design be less exposed to the penalties of the law than those
who originated it ? Would not their concurrence, without any par-
ticular proof of an agreement to concur, be conclusive against
them? If it had been proved that the defendant in this case had
met persons in Orleans County who had Morgan in their custody,
and on being made acquainted with their views had expressed his
approbation of their original undertaking and given them his aid in
accomplishing it, would he have not been involved in the conspir-
acy ? I cannot bring my mind to entertain a doubt on the subject.
But it may be said that the case supposed shows a new conspiracy.
388 Cases on Criminal Law.
I concede that it does ; but it shows a new conspiracy no more
than one would be shown by proving that the defendant assisted in
carrying the conspiracy into execution after it was formed. It may
be that the judge only meant to say that the acts of the defendant
being merely in furtherance of the design of the conspirators would
not make him a party to the conspiracy. They certainly would
not unless he knew of the designs of the conspirators and inten-
tionally lent his aid to them. It is settled on good authority that
the fact of conspiring need not be proved. 2 Day's Rep. 205 ; i
Wm. Black. Rep. 392. If parties concur in doing the act, although
they were not previously acquainted with each other, it is a con-
spiracy, per Lord Mansfield, i Hawk. ch. 72, § 2, note. Lord
Kenyonsays in The King v. Hammond & Webb, 2 Esp. Cas. 719,
" If a general conspiracy exists, you may go into general evidence
of its nature and the conduct of its members, so as to implicate men
who stand charged with acting upon the terms of it, years after those
terms have been estabhshed, and who reside at a great distance
from the place where the general plan is carried on." These cases
show that all who accede to a conspiracy after its formation and
while it is being executed, become conspirators. I am of opinion
that the judge misdirected the jury as to the law when he stated to
them that the defendant, if he was not a party at the formation of
the conspiracy originally, would not become such by assisting to
carry it into execution.
But under the circumstances of this case I entertain serious
doubts whether the court ought (assuming that it has the right) to
grant a new trial for this misdirection. In ordinary cases the court
do not grant a new trial if the judge has misstated the law to the
jury unless it is probable that the result of the trial has been thereby
changed. In criminal cases, where the defendant has once been
acquitted, the reluctance to grant new trials has ever been very
great. It is a conceded rule of law not to grant a new trial in such
cases because the verdict is against evidence. Whether a new trial
can be granted where there has been an acquittal without infring-
ing the rights of the defendant, even where the court have misdi-
rected the jury, is now an unsettled question. If the power exists
it ought not to be exercised unless it is reasonable to infer that the
misdirection of the court has been the cause of the acquittal. Was
the verdict of acquittal in this case the result of the judge's error
-Cases on Criminal Law. 389
as to the law ? I do not believe that we should be warranted in
saying that it was. I do not, however, mean to be understood
that I approve of the verdict of the jury. This court look at the
facts only with a view to ascertain and settle the questions of law
that arise in the case.
It is insisted that the indictment in this case is insufficient be-
cause it does not contain a particular specification of the crime and
does not set forth the overt act relied on as evidence to manifest
the defendant's guilt. The first count charges the defendant with
having conspired and combined, &c., at Gaines, in the county of
Orleans, with divers persons unknown, unlawfully to harass, vex,
oppress, assault and falsely imprison one William Morgan, &c.
The decision in Lambert's case, 9 Cowen, 578, was that if an in-
dictment for a conspiracy does not set forth the object specifically
and show that such object is a legal crime, it should state particu-
larly the means intended to be used by the conspirators and show
that those means are criminal. This rule has not, though the de-
fendant's counsel supposed it had, a particular application to the
case before us, because this indictment sets forth a legal crime as
the object of the conspiracy, the false imprisonment of a citizen.
The crime explicitly appears. In relation to stating overt acts in
the indictment, I apprehend the counsel for the defendant has been
misled as to the law by assimilating conspiracy to treason. In sev-
eral respects there is an analogy between them, but the necessity
of setting forth overt acts in an indictment for treason arises from
statutory provisions which were not made, as I conceive, in affirm-
ance of the common law. The offence in treason is an act of the
mind, but as it could be proved only by external acts, there was
much reason for requiring (as several acts of Parliament have done)
some of those acts to be stated. This is a deviation from the com-
mon rule in pleading, which requires the crime or cause of action
to be stated, and not the evidence by which it is to be proved.
The compassing the death of the king is treason ; the overt acts are
the means made use of to effectuate the intentions or imaginations
of the heart. The overt acts, as they are the only things that can
be proved, are the charges to which the accused is to answer. Fos-
ter, 194. No person can be convicted of treason against whom
an overt act cannot be proved, but this is not the case in conspir-
acy ; it is not a mental offence ; it does not consist in intents and
390 Cases on Criminal Law.
imaginations. It exists where there are no overt acts other than
the agreement. I have alluded already to several authorities
which declare that conspirators may be convicted if no act has been
done towards the accomplishment of their designs. This cer-
tainly could not be the case if an overt act must be set forth in the
indictment. Mr. Chitty says it is usual to frame the indictment
stating the conspiracy, and then showing that in pursuance of it
certain overt acts were done, but it is holden sufficient to state the
conspiracy alone. 3 Chit. C. L. 909 ; 2 Lord Ray, 1 1 67, S. C. ; i
Salk. 1 74. Starkie declares that a general averment that the de-
fendant did conspire, &c., to accompUsh an object apparently crim-
inal is sufficient without showing in what manner and by what
means the conspiracy was to be produced. In strictness it is not
necessary to allege any overt act done in pursuance of the criminal
design. Stark. C. PL 170, i. In Rex v. Kinnersly and Moore, i
Str. 193, it was decided that no overt act need be laid in the indict-
ment, and several cases are there referred to wherein such indict-
ments were held good.
It is supposed that a conspiracy to commit a crime is merged
in the crime when the conspiracy is executed. This may be so
where the crime is of a higher grade than the conspiracy and the
object of the conspiracy is fully accomplished, but a conspiracy is
only a misdemeanor, and when its object is only to commit a mis-
demeanor it cannot be merged. Where two crimes are of equal
grade there can be no legal technical merger. This court had this
question under consideration in the case of Bruce, and there inti-
mated an opinion that a conspiracy to commit a misdemeanor was
not merged in the misdemeanor when actually committed.
As those who were concerned with the defendant, if he was
one of the conspirators, or some of them, were known (as it ap-
peared on the trial they were) to the grand jury when the indict-
ment in this case was found by them, the allegation therein that
the defendant conspired with persons unknown is improper, it is
said, and that on such an indictment the defendant cannot be con-
victed. An indictment should contain so much certainty as clearly
to designate not only the particular kind of offence, but the spe-
cific criminal act for which the accused is to answer. If there has
been a murder the name of the person killed must, if it can be
ascertained, be stated in the indictment. This the accused may rea-
Cases on Criminal Law. 391
sonably require, that he may know what he has to answer ; but if he
had associates I apprehend that they need not be named, because a
charge of that nature may be made sufficiently certain without a
disclosure of their names. So if a person is charged with a larceny,
the indictment ought to show who was the owner of the goods
stolen that the accused may know for what act he was to answer.
But in a charge of conspiracy it seems no more necessary to specify
the names of the defendant's coadjutors than in an indictment for
an assault and battery to name others besides the accused who
were concerned in the trespass, if the fact were really so. In Kin-
nersley and Moore a case is mentioned where this point was di-
rectly passed on. The bill presented to the grand jury charged
that Heme with A and cum multis aliis conspired to accuse B of
a felony. The grand jury returned the bill with an ignoramus as
to A. Then the charge against Heme as presented by the indict-
ors was that he with many others conspired, &c. The indictment
was objected to as insufficient on a motion to arrest the judgment,
but the court denied the motion and said the indictment was suffi-
cient, it being found that Heme with many others did conspire, &c.,
and it might have been so laid at first. Where a person was in-
dicted for engrossing hay and straw, and the act was charged to be
done by him and twenty-seven others, an exception was taken to
the indictment that the names of each person of the twenty-seven
was not set forth ; it was overruled on the ground that it was not nec-
essary to set out their names. Cro. Car. 380. It does not appear
that the persons not named were unknown or that the indictment
in either case charged them to be unknown. I am satisfied on
reason and authority that the objection taken to the indictment in
this case on this account is not sustainable.
Motion for a new trial denied.
392 Cases on Criminal Law. i
DILL V. STATE.
Court of Criminal Appeals of Texas, 1895.
35 Texas Criminal Reports, 240.
Hurst, P. J. The indictment in this case contains two counts :
the first for burglary, the second for conspiracy to commit the
same burglary. Appellant was convicted for the conspiracy.
Counsel for appellant requested the court to give to the jury
this charge : " If you believe from the evidence that the defend-
ant, Steve Dill, agreed and conspired with W. D. Dill to burglarize
the store of R. J. Waters, but before the defendant or W. D. Dill
did any act to carry out said agreement Steve Dill revoked and
abandoned his part of the agreement and told said W. D. Dill that
he (Steve Dill) would have nothing to do with said contemplated
burglary, then the defendant in that case would not be guilty." If
this instruction was intended to be applied to the burglary, then
the refusal worked no injury to appellant, because he was acquitted
of that offence. If it had reference to the conspiracy, then it did
not contain the law, because when the appellant and W. D. Dill
entered into a positive agreement to commit the burglary, the
offence — namely, conspiracy — was complete, and a withdrawal
therefrom is no atonement for the offence consummated. The
judgment is affirmed.'
SECTION III.
AUTHORIZED ACTS.
(a) Acts in Furtherance of Public Justice.
This kind of occision of a man according to the laws of
the kingdom and in execution thereof ought not to be numbered
in the rank of crimes, for it is the execution of justice, without
^ Part of the opinion only is printed.
Cases on Criminal Law. 393
which there were no living, and murders, burglaries, and all capital
crimes would be as frequent and common, as petit trepasses and
batteries. The taking away of the life, therefore, of the malefactor
according to law by sentence of the judge, and by the sheriff or
other minister of justice pursuant to such sentence, is not only an
act of necessity, but of duty, not only excusable, but commendable,
when the law requires it. * * * The deliberate, un-
compelled extrajudicial killing of a person attaint of treason,
felony, or murder, or in 2l prcemunire, tho' upon the score of their
being such, is murder.
Therefore it is necessary (i) That he that gives sentence of
death against a malefactor, be authorized by lawful commission or
charter, or by prescription to have cognizance of the cause. (2)
That he that executes such sentence be authorized to make such
execution, otherwise it will be murder or manslaughter, or at least
a great misprision in the judge that sentenceth, or in the minister
that executeth. / Hale, P. C, 496.
LEONIN'S CASE.
Worcestershire Eyre, 1221.
Select Pleas of the Crown. Sel. Sac. PL, 133.
Leonin, Phillips' son, and Jacob his servant slew John of
Middleton in the forest of Kinfare and fled and were dwelling in
Staffordshire in the township of Kinfare. And therefore this must
be discussed at Stafford. Let them be exacted and outlawed.
Inquiry as to their chattels must be made at Stafford. Englishry
is presented.
Afterwards came John, Phillip's son, Robert of Stapleton and
Adam of Peissi and undertook to produce Leonin and Jacob before
the justices at Stafford to abide judgment. So the sheriff is
ordered that the exacting and outlawing be respited until they
shall have another order.
At Lichfield came Leonin and Jacob and put themselves upon
their verdict as to when, where, and by whom the deed was done.
The jurors of the hundred of Seisdon say that in the time of the
394 Cases on Criminal Law.
war John came with many others into the king's forest to offend
in the forest, as was his wont, and was found seised of the whole
body of a doe, and the king's servants and foresters could not
take him alive, and he defended himself against our lord the king
and cut off a forester's finger, and thus it was that he was slain. And
so it is considered that [Leonin and Jacob] be quit thereof.^
UNITED STATES v. RICE.
United States Circuit Court for North Carolina, 1875.
I Hughes, 560.
On the 1 5th of last September, Andrew Woody, of Spring
Creek, Madison County, was killed by Noah H. Rice, a United
States deputy marshal, who was endeavoring to serve a capias on
him for violation of the Internal Revenue Laws. From facts de-
veloped before the court it appears that Woody had expressed a
determination to resist any process which might issue against him,
and had threatened to kill the defendant Rice if he attempted to arrest
him. When this officer came upon Woody the latter was armed with
a rifle. His demeanor was hostile, and when commanded to sur-
render he so acted as to impress the officer with the belief that
his intention was to shoot him, and in self-defence he fired upon
Woody with fatal effect. Rice came to Asheville and surrendered
himself to the authorities, was examined by Commissioner Watts
on application for bail, and committed to jail. His case was finally
removed to the United States court, on Tuesday, May nth, 1875.
He was placed upon trial for his life. The jury having requested
full instructions from the bench, they were given as follows by
Dick, J. As this is a case of considerable importance to the
defendant, and also to the due administration of justice, I have
deemed it proper to commit to writing my instructions to the jury
upon the questions of law involved.^
It is conceded that the alleged homicide was committed by
1 See also Anon. Y. B. 30 & 31 Edw. I, 512 (1302). — Ed.
^ Part of the charge is omitted.
Cases on Criminal Law. 395
the defendant, and he places his defence upon the ground that he
was a regular constituted officer of the United States, and had in
his hands at the time of the homicide the process of law which
authorized and commanded him to arrest the deceased for a crime
against the United States ; that the deceased resisted the execution
of such process with a deadly weapon in his hands, and had mani-
fested a purpose to use such deadly weapon in resistance ; and
that the homicide was necessarily committed in the attempt to make
an arrest.
This defence necessarily leads us to inquire what protection the
common law affords to ministerial officers, and how far they are
authorized to go in the performance of their public duties.
Social order and political government are dependent upon the
observance of law by the citizen. The mandates of the law are
executed by officers provided for such purposes, and such officers
are invested by the law with the authority necessary to execute its
mandates, and it affords them all the protection possible in the
rightful performance of the duties imposed. This rule is absolutely
necessary for the advancement of justice, and is founded in wisdom
and equity and in the principles of social and political order. The
law must be supreme within the sphere of its operation, or its
influence would be nugatory, and there would be no certain rule
to regulate human conduct in society and government, and all the
rights and liberties of citizens would soon be lost in a chaos of
anarchy.
Mr. Justice Foster says : " Ministers of justice while in the
execution of their offices are under the peculiar protection of the
law." (Foster, 308.) If an officer is killed while performing his
duty, the law deems such killing murder oi malice prepense.
This protection is not confined to the precise time when the
officer is performing his official duty, but extends over him while
going to, remaining at, and returning from the place of action. Any
opposition, obstruction, or resistance intended to prevent an officer
from doing his official duty, is an indictable offence at common
law, and the punishment is regulated by the nature of the offence.
An officer is authorized to summons as many persons as may
be necessary to assist him in the performance of his legal duties,
and such persons are bound to obey such summons, and they are
under the same protection afforded to officers, as they are for the
396 Cases on Criminal Law.
time officers of the law. The law imposes upon private persons
the duty of suppressing affrays, preventing felonies from being
committed in their presence, and arresting such offenders and
bringing them to justice; and such private persons, while performing
their duties, are under the protection of the law. We may confi-
dently lay down the broad general principle, that when any person
is performing a public duty required of him by law, he is under the
protection of the law. An officer of the law who has legal process
in his hands is bound to execute it according to the mandate of
the writ. If he is resisted in the performance of this duty, he mu.st
overcome such resistance by the use of such force as may be
necessary for him to execute his duty. If necessary, the law
authorizes him to resort to extreme measures, and if the resisting
party is killed in the struggle the homicide is justifiable. Garrett's
Case, N. C. R., 144, Winston.^
If unnecessary and excessive force is used, after resistance has
entirely ceased and the defendant in the writ has manifested his
willingness to submit to the mandates of the law and be arrested,
then if the said defendant is killed, the officer will be guilty of man-
slaughter ; and if the blood had time to cool, the killing would be
murder. 2 Wharton, Crim. Law, 1030— 31, and authorities referred
to in note.^ If, however, the defendant in the writ only ceases his
resistance upon the officer desisting from his attempt to arrest, and
still keeps himself in a condition to renew the resistance with a
deadly weapon, if the officer should renew the effort to arrest, and
the officer cannot make the arrest without great personal danger
he would be justified in killing the defendant. The submission of
the defendant in such a case is not complete, and as long as he
refuses to be arrested he is in a state of resistance ; and if he is
armed with a deadly weapon, and has manifested an intent to use
it, and still keeps the weapon in his possession convenient for an
emergency, and the officer has reasonable grounds for believing
that the weapon will be used if an arrest is attempted, the officer is
1 Accord: U. S. v. Jailor, 2 Abb., 265 (1867); Smith v. St., 26S. W.
(Ark.) 712(1894); St. V. Gosnell, 74 Fed., 734(1896); Lynn z/. P., 170 III.,
527 (1897); Contra, where arrest is for a misdemeanor; Stephens v. C. , 47 S.
W. (Ky.)229 (1898).
''Accord: Gosse's Case, Ventr., 216(1673); St. v. Rose, 142 Mo.,
4i8(i897)-ED. ^ ^
Cases on Criminal Law. 397
not required to risk his life in a rencounter, or desist from an effort
to perform his duty. When a person puts himself in an armed and
deadly resistance to the process of the law, he becomes virtually an
outlaw, and officers are not required to show him the courtesy of
a chivalrous antagonist and give him an open field and fair fight.
It is only when a criminal submits to the law that it throws round
him the mantle of protection and administers justice with mercy.
It is the duty of every offender charged with crime in due process
of law to quietly yield himself up to public justice. State v. Bryant,
65, 327 ; State v. Garrett's Case, Winston, 144.
A known officer, in attempting to make an arrest by virtue o
a warrant, is not bound to exhibit his warrant and read it to a
defendant before he secures him, if he resists ; if no resistance is
offered, the officer ought always, upon demand made, show his
warrant to the party arrested or notify him of the substance of the
warrant, so that he may have no excuse for placing himself in
opposition to the process of the law. This is only a rule of pre-
caution. A defendant is bound to submit to a known officer ; to
yield himself immediately and peaceably into the custody of the
officer before the law gives him the right of having the warrant
read and explained ; when in resistance, the law shows him no
favor. A defendant, knowing the arresting party to be an officer,
is bound to submit to the arrest, reserving the right of action against
the officer in case the latter be in the wrong. When a person acts
in a public capacity as an officer, it will be presumed that he was
rightfully appointed. (i Wharton Cr. L., Sees. 1289, 2925 ;
Cooky's Case, 6 Gray, Mass., 350.)
One who is not a known officer ought to show his warrant and
read it, if required ; but it would seem that this duty is not so
imperative as that a neglect of it would make him a trespasser ab
initio, when there is proof that the party subject to be arrested had
notice of the warrant, and was fully aware of its contents, and had
made up his mind to resist its execution at all hazards. (Garrett's
Case, supra.)
The law, in its humanity and justice, will not allow unneces-
sary force to be used in the execution of its process. If a defendant,
without any deadly weapon or manifestation of excessive violence,
makes resistance, an officer is not justified in wilfully shooting him
down ; but if a defendant has a deadly weapon, and has manifested
398 Cases on Criminal Law.
a purpose to use it if an arrest is attempted, the officer is not bound
to wait for him to have an opportunity of carrying his purpose into
effect. If the warrant is for a misdemeanor and a defendant attempts
to avoid an arrest by flight, the officer has no right to shoot him
down to prevent escape, nor even after an arrest has been made
and defendant escapes from custody. (Foster's Case, i L. C. C.
The rule is different in cases of felony. (Bryant's Case, supra.f
If an officer has process in his hands issuing from a court of
competent jurisdiction over the subject-matter, authorizing and
commanding him to arrest a defendant, he is entitled to the pro-
tection which the laws afford officers acting under process, although
the process in his hands is informal and irregular. If the process
is illegal and void on its face, or is against the wrong person, or its
execution is attempted out of the district in which it can alone be
executed, then the officer would not be under the protection of the
law ; but it would seem that if he kills a resisting party under such
circumstances, he would only be guilty of manslaughter, unless he
had actual knowledge of his want of authority, or acted from
express malice.
I have stated to you many points of law which do not directly
arise in the case before us ; but it is important that they should be
known and well understood in the country, where, in recent years,
so much violence has been committed — violence in the name of law
and violence in the defiance of law.
The principles of law involved in this case having been ex-
plained to you by the court, it is now your duty to ascertain the
facts from the testimony and apply them to the law as laid down
by the court.
The jury, after a retirement of two hours, found a verdict of
"not guilty."
1 Accord: Reneau i/. St., 2 Lea, 720 (1879); Handley v. St., 96 Ala,,
48(1891). — Ed.
2 Accord: Carr v. St., 43 Ark., 99 (1884). — Ed.
Cases on Criminal Law. 399
AUTHORIZED ACTS. {Continued)
{b) Acts in Furtherance of Domestic Authority.
BRADLEY AGAINST HIS WIFE.
King's Bench, 1663.
I Keble, 637.
3.' They refused to bind him to the peace at her suit, unless
her life be in danger, because by the law he hath power of castiga-
tion ; and the Bishop of London had certified he used to beat
her, but that she used to provoke him ; and that by reason of their
wilfulness he could not end their difference, according to the refer-
ence of the court last term.
STATE V. OLIVER.
Supreme Court of North Carolina, 1874.
70 North Carolina, 60.
Settle, J. We may assume that the old doctrine, that a
husband had a right to whip his wife, provided he used a switch
no larger than his thumb, is not law in North Carolina. Indeed,
the Courts have advanced from that barbarism until they have
reached the position, that the husband has no right to chastise his
wife, under any circumstances.^
But from motives of public policy, — in order to preserve the
sanctity of the domestic circle, the Courts will not listen to trivial
complaints.
If no permanent injury has been inflicted, nor malice, cruelty
nor dangerous violence shown by the husband, it is better to draw
the curtain, shut out the public gaze, and leave the parties to forget
and forgive.
^ The first and second resolutions are omitted.
2 Accord ; P. v. Winters, 2 Park. C. R. 10 (1823) ; St v. Buckley, 2
Harr. 552 (1838) ; C. v. McAfee, 108 Mass. 458 (1871).— Ed.
400 Cases on Criminal Law.
No general rule can be applied, but each case must depend
upon the circumstances surrounding it.
Without adverting in detail to the facts established by the
special verdict in this case, we think that they show both malice
and cruelty.
In fact, it is difficult to conceive how a man, who has promised
upon the altar to love, comfort, honor, and keep a woman, can lay
rude and violent hands upon her, without having malice and cruelty
in his heart.
Let it be certified that the judgment of the Superior Court is
affirmed.
Per Curiam. Judgment affirmed}
GREY'S CASE
Old Bailey, 1666.
Kelyng, 64.
John Grey being indicted for the murder of William Golding,
the jury found a special verdict to this effect, viz : We find that
the day, year, and place in the indictment mentioned, John Grey,
the prisoner, was a blacksmith, and that William Golding, the per-
son killed, was his servant, and that Grey, his master, commanded
him to mend certain stamps, being part belonging to his trade,
which he neglected to do ; and the said Grey, his master, after
coming in asked him, the said Golding, why he had not done it,
and the said Grey told the said Golding, that if he would not serve
him, he would serve in Bridewel, to which the said Golding replied
that he had as good serve in Bridewel as serve the said Grey his
master ; whereupon the said Grey, without any other provocation,
struck the said Golding with a bar of iron, which the said Grey
then had in his hand, upon which he and Golding were working
at the anvil, and with the said blow he broke his skull, of
which he died ; and if this be murder, etc. This case was found
=* Accord : Bradley z/. St, i Walker, 156 (1824). — Ed.
"It is sickly sensibility which holds that a man may not lay hands
on his wife, even rudely, if necessary, to prevent the commission of some
unlawful or criminal purpose." Armstrong, J., in Richards 7/. Richards,
I Grant (Pa.) 389(1856.)
Ca3es on Criminal Law. 401
specially by the desire of my brother Wylde, and I showed the
special verdict to all my brethren, Judges of the King's Bench,
and to my Lord Bridgman, Chief Justice of the Common Pleas.
And we were all of opinion that this was murder. For if a father,
master, or schoolmaster, will correct his child, servant, or scholar,
they must do it with such things as are fit for correction, and not
with such instruments as may probably kill them. For otherwise,
under pretence of correction, a parent might kill his child, or a mas-
ter his servant, or a schoolmaster his scholar, and a bar of iron is no
instrument for correction. It is all one as if he had run him through
with a sword ; and my Brother Morton said he remembered a case at
Oxford Assizes before Justice Jones, then Judge of Assize, where
a smith being chiding with his servant, upon some cross answer
being given by his servant, he having a piece of hot iron in his
hand, run it into his servant's belly, and it was judged murder, and
the party executed. And my Lord Bridgman said, that in his
circuit there was a woman indicted for murdering her child, and it
appeared upon the evidence, that she kicked her and stamped
upon her belly, and he judged it murder; and my Brother Twis-
den said, he ruled such a case formerly in Gloucester Circuit,
for a piece of iron or a sword, or a great cudgel, with which
a man probably may be slain, are not instruments of correction.
And therefore when a master strikes his servant willingly with
such things as those are, if death ensue, the law shall judge it
malice prepensed.
But if a parent, master, or schoolmaster, correct his child,
servant, or scholar, with such things as are usual and fit for
correction, and they happen to die, Poulton de pace, page 120,
saith this is by misadventure, and cites for authority, Kelloway,
108, a, b, and 136, a. But that book, which puts this case in
Kelloway is 136, a, saith, that if a man correct his servant, or
lord his villain, and by force of that correction he dieth, although
he did not intend to kill him, yet this is a felony, because thay
ought to govern themselves in their correction in such ways that
such a misadventure might not happen. And I suppose, because
the word misadventure is there used, therefore Poulton concludeth
(it may be truly) that it is but misadventure.*
I The prisoner was pardoned.
402 Cases ON CRiMiisrAL Law.
COMMONWEALTH v. SEED.
Common Pleas of Philadelphia, 1851.
5 Clark, 78.
This was a habeas corpus.
The opinion of the court was delivered by
Parsons, J. This is an application for the discharge of the
defendants, who are teachers in one of our public schools, who
are accused with an assault and battery by the unreasonable correc-
tion of one of their pupils. And the simple question for decision
is, whether from the facts disclosed, they have been guilty of a
violation of the law.
In this city and county, where we are annually expending
nearly ^350,000 for the purpose of Common School Education,
where our schools number more than 50,000 children, with the
appropriate number of teachers for their instruction, it is important
that the law as to the rights of each, should be correctly under-
stood ; and as it is feared it is not, a few moments will be occupied
in giving what I conceive to be the settled principles of the com-
mon law upon this subject.
The right of a parent to correct his minor child, is understood.
It is one of the first rules in our domestic relations ; and yet it is
equally clear that the parent may be held responsible for the cruel
or. barbarous treatment of his child. The school teacher, while a
child is placed by the parent or guardian in school, or under charge
of the teacher, is in loco parentis, and can exercise the same author-
ity as the parent, and is responsible in the same manner, and the
rules of law which are applicable to the parental control, are also
to be applied to the school teacher.
An able and accomplished American law writer, has now
given us a plain and intelligent rule, which I will quote at length.
When writing upon this subject, he says :
"The parent has a right to govern his minor child, and as
incident to this, he must have power to correct him. The maxim
is, that he has power to chastise him moderately. The exercise
of this power must be, in a great measure, discretionary. He may
so chastise his child as to be liable in an action by the child
Cases on Criminal Law. 403
against him for a battery. The child has rights which the law-
will protect against the brutality of a barbarous parent. I appre-
hend, however, it is a point of some difficulty to determine with
exact precision, when a parent has exceeded the bounds of mod-
eration. That correction which will be considered by some triers
as unreasonable, will be viewed by others as perfectly reasonable.
What may be considered by some a venial folly, to which none, or
very little correction ought to be applied, by others will be con-
sidered as an offence that requires very severe treatment. The
parent is bound to correct a child so as to prevent him from
becoming the victim of vicious habits, and thereby proving a nui-
sance to the community. The true ground on which this ought to
be placed, I apprehend is, that the parent ought to be considered
as acting in a judicial capacity when he corrects, and, of course,
not liable for errors of opinion. And although the punishment
should appear to the triers to be unreasonably severe, and in no
measure proportioned to the offence, yet if it should also appear
that the parent acted conscientiously and from motives of duty,
no verdict ought to be found against him.
" But when the punishment is, in their opinion, thus unrea-
sonable, and it appears that the parent acted malo animo, from
wicked motives, under the influence of an unsocial heart, he ought
to be liable to damages. For error of opinion he ought to be
excused, but for malice of heart he must not be shielded from the
just claims of the child. Whether there was malice may be col-
lected from the circumstances attending the punishment. The
instrument used, the time when, the place where, the temper of
heart exhibited at the time, may all unite in demonstrating what
the motives were which influenced the parent. These observations
are equally applicable to the case of a schoolmaster, or to any one
who acts in loco parentis." Reves' Domestic Relations, 288 ; i
Blacks, Com. 58.
To the doctrine here laid down we entirely assent, for it is
unquestionably the law, based upon the soundest principles which
control civil society.
To render a parent liable to prosecution by his minor child, he
must be governed by motives of malice or wickedness. For a
mere error of judgment influenced, perhaps, by fond parental love
for the future prosperity and happiness of his child, he cannot be
404 Cases on Criminal Law.
held legally liable. The law does not permit a court to invade
the sanctuary of the domestic circle and usurp the parental
authority in every family, because we may think the punishment is
severe. It is only when, from the surrounding facts and circum-
stances of the case there is strong reason to believe that the parent
has been actuated by bad and malevolent motives, using his legal
parental authority for the gratification of a mind bent on mischief,
that the law has given the court the right to interpose for the pro-
tection and safety of the child. Such is the rule relative to the
school teacher, whom the parent, for the time being, has placed in
his stead.
Let us, then, apply the rule to the facts of the present case.
What is there in this case which shows a wicked motive or malice
on the part of the teacher ? Is there anything which shows even
passion or temper ?
The child had played truant. It was arrested by the parent
and sent with an elder sister to school; when brought to the door
of the schoolroom, she refuses to go in ; begins to show great
violence of temper and rebellion ; an assistant teacher tries to
soothe the child, and uses persuasion to induce her to enter the
schoolroom. The elder sister communicates the request of the
mother that the child be taken to school. The principal teacher
then comes and takes the child into the schoolroom, when the
spirit of rebellion continues, manifested by screaming and jump-
ing. The teacher talks to the child, urges obedience in mildness,
then commands it, and finally threatens chastisement ; but all this
to no purpose. Then it is she flogs the child with a small rattan.
After a few blows, she stops, reasons with the child, but exacts
obedience, and still uses persuasion. The child is still obstinate,
and further chastisement is inflicted, till finally the obstinate and
rebellious spirit is conquered.
What is there in all this which shows malice or cruelty on the
part of the teacher ? What is there in the language of the law
which shows a " wicked motive ? " I can see nothing. The
teacher required obedience to the rules of the school and it was
refused. That punishment is used which she thinks is best cal-
culated to produce submission, and in the manner and form com-
mon in all schools. This authority the law has delegated to her,
and for the exercise of it, although we might differ in opinion as
Cases on Criminal Law. 405
to the manner in which it was done, at least the court will not
punish for, or correct an error of judgment. But from the facts
disclosed I do not think there was even an error in that particular.
She entered upon the performance of her duty with moderation
and firmness, as well as a determination to produce submission,
which she pursued till it was accomplished by the biest means her
judgment dictated. In this we think she was right. Had she
done less, the directors of the school might with propriety have
thought she was culpable ; and for these things the law does not
hold her responsible.
But it has been said there were marks of violence on the child
the next day, caused by blows from the rattan. But this is but a
slight circumstance to show the motive. It is much greater
evidence of the obstinacy and perseverance of the child. The
instrument employed was a small, smooth rattan, certainly a
moderation in the instrument used in these days of improvement
in education, and in most that is useful or which adds to the
comfort of man. For many of us can well recollect when the
birch, or hickory stick, with some rather sharp knots thereon, was
the instrument for flagellation, and our parents did not complain.
To hold that under such circumstances, a teacher shall be
liable to a criminal prosecution, would be subversive of all govern-
ment and order in our schools. Without a firm controlling power
is exercised by school teachers, in exacting obedience, submission,
united with quiet and good order in their schools, the public money
is worse than wasted. Obedience to parental authority should
be taught in the family, and must be maintained in our schools,
or we shall have no obedience to the laws of our government.
To the want of the proper exercise of strict parental control among
a large class of citizens, may be traced in a great degree, the spirit
of insubordination, disobedience of law, and the outrages upon the
rights of others, that are so frequent among us. Much may be
hoped from the influence of our public schools, if the teachers are
faithful in teaching and exacting obedience from all under their
charge.
The character and interest of the teacher, combined with the
refinement which education gives to the human mind in softening
the heart, like parental love, is generally found a sufficient protection
for the children. But if these fail, the law affords ample protec-
4o6 Cases on Criminal Law.
tion against cruelty and oppression, while it is a shield to those
who, in their sphere, have, as in this case, only done their duty.
For the reasons given we order the defendant to be discharged.^
AUTHORIZED ACTS. {Continued)
(c) Acts in Prevention of Crime.
HOWELL'S CASE.
Worcestershire Eyre, 1221.
Select Pleas of the Crown. Sel. Soc.'^Pl., 145.
Howell, the Markman, a wandering robber, and his fellows
assaulted a carter, and would have robbed him, but the carter slew
Howell and defended himself against the others and escaped. And
whereas it is testified that Howell was a robber, let the carter go
quit thereof. - And note that he is in the parts of Jerusalem, but
let him come back safely, quit of that death.
STOREY V. STATE.
Supreme Court of Alabama, 1882.
71 Alabama, 329.
Somerville, J.'^ The record contains some evidence remotely
tending to show that the prisoner was in pursuit of the deceased
for the purpose of recapturing a horse, which the deceased had
1 Accord : Stepfather, St. v. Alford, 68 N. C, 322 (1873); master
and apprentice, St. v. Dickinson, 98 N. C., 708 (1887).
Contra: Hirer of Convicts, Prewitt v. St. 51 Ala., 33 (1874);
keeper of almshouse, St. v. Hull, 34 Conn., 132 (1867), unless necessary
to preserve present order. St. v. Neff, 58 Ind., 516 (1877). —Ed.
' Part of the opinion is omitted.
Cases on Criminal Law. 407
either stolen, acquired by fraud, or else unlawfully converted to his
own use.
If the property was merely converted, or taken possession of
in such manner as to constitute a civil trespass, without any crinir
inal intent, it would not be lawful to recapture it by any exercise of
force which would amount even to a breach of the peace, much
less a felonious homicide. Street v. Sinclair, ante, p. no; Burns
V. Campbell, ante, p. 271.
Taking the hypothesis that there was a larceny of the horse,
it becomes important to inquire what would then be the rule.
The larceny of a horse is a felony in this State, being specially
made so by statute, without regard to the value of the animal
stolen. Code, 1876, § 4358. The fifth charge requested by the
defendant is an assertion of the proposition, that if the horse was
feloniously taken and carried away by the deceased, and there was
an apparent necessity for killing deceased in order to recover the
property and prevent the consummation of the felony, the homi-
cide would be justifiable. The question is thus presented, as to the
circumstances under which one can kill in order to prevent the
perpetration of a larceny which is made a felony by statute — a
subject full of difficulties and conflicting expressions of opinion
from the very earliest history of our common law jurisprudence.
The broad doctrine intimated by Lord Coke was, that a felon may
be killed to prevent the commission of a felony without any
inevitable cause, or as a matter of mere choice with the slayer.
3 Inst. 56. If such a rule ever prevailed, it was at a very
early day, before the dawn of a milder civilization, with its wiser
system of more benignant laws ; for Blackstone states the prin-
ciple to be, that " where a crime, in itself capital, is endeavored to
be committed by force, it is lawful to repel that force by the death
of the party attempting." 4 Com. 181. The reason he assigns
is, that the law is too tender of the public peace and too careful
of the lives of the subjects to " suffer, with impunity, any crime to
be prevented by death, unless the same, if committed, would also
be punished by death." It must be admitted that there was far
more reason in this rule than the one intimated by Lord Coke,
although all felonies at common law were punishable by death, and
the person killing, in such cases, would seem to be but the execu-
tioner of the law. Both of these views, however, have been
4o8 Cases on Criminal Law.
repudiated by the later authorities, each being to some extent
materially modified. All admit that the killing cannot be done
from mere choice ; and it is none the less certain that the felony
need not be a capital one to come within the scope of the rule.
Gray v. Combs, 7 J. J. Marsh. 478 ; Cases on Self-Defence (Horn
& Thomp.), 725, 867; Oliver v. The State, 17 Ala. 587; Carroll
V. The State,. 23 Ala. 28.
We find it often stated, in general terms, both by text writers
and in many well considered cases, that one may, as Mr. Bishop
expresses it, " oppose another who is attempting to perpetrate any
felony, to the extinguishment, if need be, of the felon's existence."
I Bish. Cr. Law, §§ 849-50; The State v. Rutherford, i Hawks,
457. It is observed by Mr. Bishop, who is an advocate of this
theory, that ' ' the practical carrying out of the right thus conceded,
is, in some circumstances, dangerous, and wherever admitted, it
should be carefully guarded." i Bish. Cr. Law, § 855.
After a careful consideration of the subject we are fully per-
suaded that the rule, as thus stated, is neither sound in principle,
nor is it supported by the weight of modern authority. The safer
view is that taken by Mr. Wharton, that the rule does not authorize
the killing of persons attempting secret felonies, not accompanied
by force. Wharton on Hom. § 539. Mr. Greenleaf confines
it to "the prevention of any atrocious crime attempted to be com-
mitted by force, such as murder, robbery, house-breaking in the
night-time, rape, mayhem, or any other act of felony against the
person " (3 Greenl. Ev. 115); and such seems to be the general
expression of the common law text writers, i Russ. Cr. 665-70;
4 Black. Com. 178-80; Whart. Amer. Cr. Law, 298-403 ; i East
R C. 271; I Hale P. C. 488 ; Foster, 274. It is said by the
authors of Cases on Self-Defence, that a killing which "appears to
be reasonably necessary to prevent a forcible and atrocious felony
against property is justifiable homicide." " This rule," it is added,
" the common law writers do not extend to secret felonies, or
felonies not accompanied with force," although no modern case can
be found expressly so adjudging. They further add : " It is pretty
clear that the right to kill in defence of property does not extend
to cases of larceny, which is a crime of a secret character, although
the cases which illustrate this exception are generally cases of theft
of articles of small value." Cases on Self-Defence (Horr &
Cases on Criminal Law. 409
Thomp.), 901-2. This was settled in Reg. v. Murphy, 2 Crawf. &
Dix C. C. 20, where the defendant was convicted of shooting one
detected in feloniously carrying away fallen timber which he had
stolen from the premises of the prosecutor, the shooting being done
very clearly to prevent the act, which was admitted to be a felony.
DoHERTY, C. J., said : "I cannot allow it to go abroad that it is
lawful to fire upon a person committing a trespass and larceny ;
for that would be punishing, perhaps with death, offences for which
the law has provided milder penalties." This view is supported
by the following cases: State z/. Vance, 17 Iowa, 144; McClelland
V. Kay, 14 B. Monroe, 106, and others not necessary to be cited.
See Cases on Self-Defence, p. 901, note.
There is no decision of this court, within our knowledge,
which conflicts with these views. It is true the rule has been
extended to statutory felonies, as well as felonies at common law,
which is doubtless the correct doctrine, but the cases adjudged
have been open crimes committed by force, and not those of
a secret nature. Oliver's case, 17 Ala. 587; Carroll's case, 23
Ala. 28 ; Dill's case, 25 Ala. 15.
In Pond V. The People, 8 Mich. 150, after endorsing the rule
which we have above stated, it was suggested by Campbell, J., that
there might possibly be some "exceptional cases" not within its influ-
ence, a proposition from which we are not prepared to dissent. And
again in Gray v. Combs, 7 J. J. Marsh. 478, 483, it was said
by Nicholas, J., that the right to kill in order to prevent the per-
petration of crime should depend " more upon the character of the
crime and the time and manner of its attempted perpetration, than
upon the degree of punishment attached by law." There is much
reason in this view, and a strong case might be presented of one's
shooting a felon to prevent the asportation of a stolen horse in the
night time, where no opportunity is afforded to recognize the
thief, or obtain speedy redress at law. Both the Roman and
Athenian laws made this distinction in favor of preventing the
perpetration of theft by night, allowing, in each instance, the thief
to be killed when necessary, if taken in the act. 4 Black. Com.
180, 181.
The alleged larceny, in the present case, if it occurred at all,
was in the open daylight, and the defendant is not shown to have
been unable to obtain his redress at law. Where opportunity is
410 Cases on Criminal Law.
afforded to secure the, punishment of the offender by due course of
law, the case must be an urgent one which excuses a killing to
prevent any felony, much less one not of a forcible or atrocious
nature. Whart. Hom. §§ 536-8. " No man, under the protection
of the law," says Sir Michael Foster, "is to be the avenger of
his own wrongs. If they are of such a nature for which the law
of society will give him an adequate remedy, thither he ought to
resort." Foster 296. It is everywhere settled that the law will
not justify a homicide which is perpetrated in resisting a mere
civil trespass upon one's premises or property, unaccompanied
by force or felonious intent. Carroll's case, 23 Ala. 28 ; Clark's
Man. Cr. Law, §§ 35 5-7; Whart. on Hom. § 540. The reason
is that the preservation of human life is of more importance than
the protection of property. The law may afford ample indemnity
for the loss of the one, while it utterly fails to do so for the
other.
The rule we have above declared is the safer one, because it
better comports with the public tranquillity and the peace of
society. The establishment of any other would lead to disorderly
breaches of the peace of an aggravated nature, and therefore tend
greatly to cheapen human life. This is especially true in view of
our legislative policy, which has recently brought many crimes
formerly classed and punished as petit larcenies within the class of
statutory felonies. It seems settled that no distinction can be made
between statutory and common law felonies, whatever may be the
acknowledged extent of the rule. Oliver's case, 17 Ala. 587;
Cases on Self-Def , 901, 867 ; Bish. Stat. Cr. § 139. The stealing
of a hog, a sheep, or a goat is, under our statute, a felony, without
regard to the pecuniary value of the animal. So would be the lar-
ceny of a single ear of corn, which is "a. part of any outstanding
crop." Code, § 4358 ; Acts 1880-81, p. 47. It would be shock-
ing to the good order of government to have it proclaimed, with
the sanction of the courts that one may, in the broad daylight,
.commit a wilful homicide in order to prevent the larceny of an
ear of corn. In our judgment the fifth charge requested by the
defendant was properly refused.
It cannot be questioned, however, that if there was in truth a
larceny of the prisoner's horse, he or any other private person had
a lawful right to pursue the thief for the purpose of arresting him.
Cases on Criminal Law. 41 1
and of recapturing the stolen property. Code, §§ 4668-70; I
Bish. Cr. Proc. §§ 164-5. He is not required in such case to
inform the party fleeing of his purpose to arrest him, as in ordinary
cases. Code § 4669.^ And he could, if resisted, repel force with
force, and need not give back or retreat. If under such circum-
stances, the party making resistance is unavoidably killed, the
homicide would be justifiable. 2 Bish, Cr. Law, § 647 ; I Russ.
Cr., 665 ; State v. Roane, 2 Dev., 58. If the prisoner's purpose
was honestly to make a pursuit, he would not for this reason be
chargeable with the imputation of having wrongfully brought on
the difficulty ; but the law would not permit him to resort to the
pretence of pursuit, as a mere colorable device, beneath which to
perpetrate crime.
There are some other questions raised in the record which we
do not think necessary to discuss. The judgment of the Circuit
Court must be reversed, and the cause remanded for a new trial
In the meanwhile the prisoner will be retained in custody until dis-
charged by due process of law.
AUTHORIZED ACTS. {Continued:)
(, 1
' 1,1 . ' \')\''V
' I ' i .l I'
I 1* ' ,1
ii. I
II I
I' ^ t'
i' I
•'
!,H,
II!'- 1 ' '■;" 'i
i"' I"; , , '-I
)
I
' 'Ml.'