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Hurtado v. California
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| Hurtado v. California | |
| Reference: 110 US 516 | |
| Term: 1884 | |
| Important Dates | |
| Argued: January 22, 1884 Decided: March 3, 1884 | |
| Outcome | |
| California Supreme Court affirmed | |
| Majority | |
| Morrison Waite • Samuel Freeman Miller • Joseph Bradley • William Burnham Woods • Stanley Matthews • Horace Gray • Samuel Blatchford | |
| Dissenting | |
| John Harlan | |
Hurtado v. California is a case decided 7-1 on March 3, 1884, by the United States Supreme Court holding that state criminal proceedings based on written accusations made by the prosecutor rather than a grand jury indictment do not violate the Due Process Clause of the Fourteenth Amendment. The court affirmed the decision of the California Supreme Court.[1][2]
Why it matters: The Supreme Court's decision found that state criminal proceedings that are based on a written set of accusations made by a prosecutor (known as an information), rather than by a grand jury indictment are not in violation of the Fourteenth Amendment's Due Process Clause. To read more about the impact of Hurtado v. California click here.
Background
In 1879, California adopted an article to the state constitution that permitted prosecutors to indict based on an information—a written set of accusations made by a prosecutor, rather than a grand jury. Three years later, the Sacramento County district attorney filed charges against Joseph Hurtado for the murder of Jose Antonio Stuardo. The district attorney decided to file charges against Hurtado based on an information rather than a formal investigation and indictment by a grand jury. Hurtado was arraigned and pleaded not guilty. Following a trial, he was found guilty and sentenced to death for Stuardo's murder. Hurtado appealed the decision to the California Supreme Court, arguing his right to due process was violated by not having a grand jury indictment.
The California Supreme Court upheld the charges and affirmed Joseph Hurtado's right to due process was not violated.[2]
Oral argument
Oral arguments were held on January 22, 1884. The case was decided on March 3, 1884.[1]
Decision
The Supreme Court decided 7-1 to affirm the decision of the California Supreme Court. Justice Stanley Matthews delivered the opinion of the court, with Justice John Harlan dissenting. Justice Stephen Johnson Field did not participate in the decision of this case.[2]
Opinions
Opinion of the court
Justice Stanley Matthews, writing for the court, argued that all legal proceedings, including indictments by an information, that aim to protect liberty and justice constitute due process:[2]
| “ | Tried by these principles, we are unable to say that the substitution for a presentment or indictment by a grand jury of the proceeding by information, after examination and commitment by a magistrate, certifying to the probable guilt of the defendant, with the right on his part to the aid of counsel, and to the cross-examination of the witnesses produced for the prosecution, is not due process of law.[3] | ” |
| —Stanley Matthews, majority opinion in Hurtado v. California[2] | ||
Dissenting opinion
Justice John Harlan wrote a dissenting opinion, arguing that the right to a trial by grand jury is common law in cases of capital punishment:[2]
| “ | It may be safely affirmed that, when that Amendment was adopted, a criminal prosecution, by information, for a crime involving life was not permitted in any one of the States composing the Union. So that the court, in this case, while conceding that the requirement of due process of law protects the fundamental principles of liberty and justice, adjudges, in effect, that an immunity or right, recognized at the common law to be essential to personal security, jealously guarded by our national Constitution against violation by any tribunal or body exercising authority under the general government, and expressly or impliedly recognized, when he Fourteenth Amendment was adopted in the Bill of Rights or Constitution of every State in the Union, is, yet, not a fundamental principle in governments established, as those of the States of the Union are, to secure to the citizen liberty and justice, and, therefore, is not involved in that due process of law required in proceedings conducted under the sanction of a State. My sense of duty constrains me to dissent from this interpretation of the supreme law of the land.[3] | ” |
| —John Harlan, dissenting opinion in Hurtado v. California[2] | ||
Impact
| Federalism |
|---|
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Hurtado v. California established the precedent that the right to due process does not guarantee an indictment by a grand jury in state legal proceedings, including cases of capital punishment.[1][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
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