Starr v. United States · 389

Court

Circuit Court of the United States for the Western District of Arkansas

Filed

Oct 23, 1896

Decided

Jan 4, 1897

Judge

Mr. Justice White

Posture

Second conviction after first conviction reversed by Supreme Court

Defendant (1)

Starr

Mr. A. H. Garland

Prosecution (1)

United States

Mr. Solicitor General

Overview

Judgment reversed, and case remanded with directions to grant a new trial.

Case summary

Starr v. United States is a Supreme Court case involving a defendant twice convicted of murder. The first conviction was reversed, and this appeal concerns the second conviction. The key issues were the admissibility of a warrant of arrest and affidavit, and a jury instruction on flight. The Court held the warrant and affidavit were properly admitted, as the officer's designation did not imply lack of authority under federal statute. However, the Court reversed the conviction due to an erroneous jury instruction on flight, which mirrored instructions previously deemed defective. The case was remanded for a new trial.

Abstract

The Supreme Court reviewed a second murder conviction after the first was reversed, upholding the admissibility of an arrest warrant and affidavit since the officer's designation did not imply lack of authority. However, the Court found the jury instruction on flight erroneous, mirroring prior defective instructions. The conviction was reversed, and the case remanded for a new trial.

Opinion of the court

Majority
opinionMr. Justice White

Warrant and affidavit properly admitted
Jury instruction on flight was erroneous and required reversal
Case remanded for new trial

Jurisdiction

not challenged

Subject matter

Federal criminal case

Jurisdictional facts

Writ of error sued out to review second conviction for murder

Procedural posture

Posture at trial

Second conviction after first conviction reversed by Supreme Court

Posture on appeal

Direct appeal from criminal conviction

Preserved issues

Objection to admissibility of warrant and affidavit
Objection to jury instruction on flight

Unpreserved issues

Objection to capacity of officer issuing warrant (raised on first appeal but not preserved on record)

Subsequent history

Petition for rehearing

not filed

Petition for certiorari

not filed

Legal categories

Criminal

Case record

Full case name

STARR v. UNITED STATES

Docket number

389

Court

Supreme Court of the United States

Trial court

Circuit Court of the United States for the Western District of Arkansas

Filed

Oct 23, 1896

Decided

Jan 4, 1897

Opinion author

Mr. Justice White

Opinion type

published

Precedential status

precedential

Judges on panel

Mr. Justice White

Issues & holdings

Issues raised

affirmed

reversed

Holdings

Whether the trial court erred in admitting the warrant of arrest and affidavit over objection that officer lacked authority

affirmed

Standard of review

de novo

Disposition rationale

Objection without merit; officer's designation as 'Commissioner U.S. Court' did not imply lack of authority under statute

Preservation

Issue preserved for review

Whether the trial court's jury instruction on inferences from flight was erroneous

reversed

Standard of review

de novo

Disposition rationale

Instruction identical to those previously held fatally defective by Supreme Court

Preservation

Issue preserved for review

Holdings of the court

Admissibility of warrant and affidavit

Trial court did not err in admitting warrant and affidavit; objection based on officer's designation was without merit

Officer's signature as 'Commissioner U.S. Court' did not affirmatively imply lack of authority under Rev. Stat. §627; term 'U.S. Commissioner' generally understood to mean commissioner under that statute; appointment valid even if by District Court with Circuit Court power

unanimousbinding precedent

Jury instruction on flight

Trial court's instruction on inferences from flight was erroneous and required reversal

Instruction identical to those held fatally defective in Hickory v. United States and Alberty v. United States; improperly stated flight as evidence of guilt and silent admission

unanimousbinding precedent

Error analysis

Erroneous jury instruction on flight — jury instruction · error foundNot analyzed as error required reversal · not harmless
Improper admission of warrant and affidavit — evidentiary · no error found

Statutory interpretation

Statute

Rev. Stat. §627

Question

Whether officer designated as 'Commissioner U.S. Court' has authority under statute requiring 'commissioner of the Circuit Courts'

Court's reading

Term 'U.S. Commissioner' generally understood to mean commissioner under §627; designation does not imply lack of authority

Canons applied

Plain meaningGeneral understanding

Burden of proof

Prosecution burden

Beyond a reasonable doubt

Burden met

false

Standards of review

Admissibility of warrant and affidavit — de novo Legal question of statutory interpretation reviewed de novo
Jury instruction on flight — de novo Legal correctness of jury instruction reviewed de novo

Timeline

Procedural path

Case submittedDecision issued

Events

Days, incident to ruling

Oct 23, 1896 — Jan 4, 1897

Span

Oct 23, 1896filingcited in opinion

Case submitted to Supreme Court

Supreme Court supreme court

Jan 4, 1897rulingcited in opinion

Supreme Court decision reversing conviction and remanding for new trial

Outcome: Reversed and remanded

Final disposition of appeal

Supreme Court supreme court

Facts & evidence

Key facts

5 facts

Defendant was tried twice for murder
First conviction reversed by Supreme Court
Second conviction led to this appeal
Key evidence included warrant of arrest and affidavit
Defendant allegedly fled and lived under assumed name

Disputed questions

Whether warrant was properly issued by authorized officer
Whether jury instruction on flight was proper

Procedural history

2 steps

First trial: conviction, reversed by Supreme Court
Second trial: conviction, appealed to Supreme Court

Evidence in the record

Documentary

Warrant of arrest
Affidavit

Challenged

Evidence type: Warrant of arrest · Challenge basis: Officer lacked authority under statute · Trial court ruling: admitted · Reasoning: Officer's designation did not imply lack of authority · Challenged on appeal: true · Appellate outcome: affirmed
Evidence type: Affidavit · Challenge basis: Same as warrant · Trial court ruling: admitted · Reasoning: Grounds identical to warrant · Challenged on appeal: true · Appellate outcome: affirmed

Jury

Verdict

Guilty

Jury instructions given

Instruction on inferences from flight

Jury instructions challenged

[object Object]

Sentencing

Sentence challenged on appeal

false

Objects of relevance

Warrant of arrest documentAffidavit document

Authorities

Cited authorities (5)

153 U. S. 614

followedprecedent

First appeal where conviction reversed

160 U. S. 408

followedprecedent

Precedent on erroneous flight instruction

162 U. S. 501

followedprecedent

Precedent on erroneous flight instruction

164 U. S. 492

distinguishedprecedent

Precedent with non-erroneous flight instruction

159 U. S. 596

appliedprecedent

Cited for de facto officer doctrine

Related cases (5)

Starr v. United States, 153 U. S. 614

prior appeal

Reversed first conviction

Hickory v. United States, 160 U. S. 408

precedent

Held similar instruction on flight defective

Alberty v. United States, 162 U. S. 501

precedent

Held similar instruction on flight defective

Allen v. United States, 164 U. S. 492

precedent

Held different instruction not erroneous

McDowell v. United States, 159 U. S. 596

precedent

Cited on de facto officer doctrine

Statutes

Rev. Stat. §627 (commissioner authority)
Act of June 1, 1872, c. 255, §14
Act of February 6, 1889, c. 113

Standards & doctrines

De facto officer doctrine
Plain error review

Legal principles applied

Plain error review for jury instructions
De novo review of legal questions

Notable quotes

“It is impossible to deny that, logically as well as juridically, flight is always relevant evidence when offered by the prosecution, and that it is a silent admission by the defendant that he is unwilling or unable to face the case against him.”

Trial court — Trial court's jury instruction on flight, quoted as erroneous

Illustrates improper characterization of flight as evidence of guilt

Index terms66

Summary terms

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Geo locations

Judges

Attorneys

Procedural terms

Substantive offenses

Entities and documentation

Legal actions

Action type

reversed and remanded

Target

conviction and sentence

Appealed from

Circuit Court of the United States for the Western District of Arkansas

Context

Supreme Court reversed judgment due to erroneous jury instruction and remanded for new trial

Scope

full

Further instructions

Grant a new trial

Disposition vote

unanimous

Search facets

Parties

Judges

White

Courts

Statutes cited

Practice areas

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