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Havnor v. New York

• 1897 • 170 U.S. 408 • Fuller Court
In the case of Havnor v. New York, 1897, the U.S Supreme Court ruled on a matter concerning counterfeit coins. The defendant, Havnor, was convicted in a lower court for knowingly and unlawfully possessing and attempting to sell counterfeit silver dollars. On appeal to the Supreme Court, Havnor argued that his conviction should be overturned because he had been charged with two offenses (possession and selling) but only convicted of one (selling). He claimed this violated his rights under the...Open Case
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Chief Fuller Court
Term: 1897
Docket: 227
170 U.S. 408
18 S. Ct. 631
42 L. Ed. 1087
1898 U.S. LEXIS 1555
Argued: Apr 21, 1898

Havnor v. New York

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Opinion Summary
AI Abstract

In the case of Havnor v. New York, 1897, the U.S Supreme Court ruled on a matter concerning counterfeit coins. The defendant, Havnor, was convicted in a lower court for knowingly and unlawfully possessing and attempting to sell counterfeit silver dollars. On appeal to the Supreme Court, Havnor argued that his conviction should be overturned because he had been charged with two offenses (possession and selling) but only convicted of one (selling). He claimed this violated his rights under the Fifth Amendment's Double Jeopardy Clause which protects against multiple punishments for the same offense. However, after reviewing previous cases dealing with similar issues such as double jeopardy claims involving possession and sale charges related to drugs or firearms - it was determined by Justice Edward Douglass White that these were separate crimes requiring different elements of proof; therefore they did not constitute 'the same offence'. The Supreme Court upheld Havnor’s conviction stating that both acts constituted distinct offences even though they arose from a single transaction. Therefore there was no violation of double jeopardy protections.

Dissent Summary
AI Abstract

The dissenting opinion in the case of Havnor v. New York argued that the majority's decision was inconsistent with previous rulings and infringed upon individual rights. The justice disagreed with the majority's interpretation of what constitutes a "public use" under eminent domain law, arguing that it was too broad and could potentially allow for abuses of power by government entities. They contended that private property should not be taken away from individuals unless there is a clear public benefit or necessity, which they did not believe existed in this case. Furthermore, they expressed concern about potential violations to due process rights if such expansive interpretations were allowed to stand unchallenged.

Opinion written by Justice EDEWhite
Decided: May 09, 1898
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