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Hurtado v. People Of California

• 1883 • 110 U.S. 516 • Waite Court
Hurtado v. People of California was a United States Supreme Court case that addressed the issue of whether a state could constitutionally require a grand jury indictment for a felony prosecution. The case was brought by a woman named Francisca Hurtado, who was charged with murder in California. She argued that the state's requirement of a grand jury indictment violated her rights under the Fifth and Fourteenth Amendments of the United States Constitution. The Supreme Court held that the Fifth...Open Case
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Chief Waite Court
Term: 1883
Docket: 1207
110 U.S. 516
4 S. Ct. 111
28 L. Ed. 232
1884 U.S. LEXIS 1716
Argued: Jan 22, 1884

Hurtado v. People Of California

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Opinion Summary
AI Abstract

Hurtado v. People of California was a United States Supreme Court case that addressed the issue of whether a state could constitutionally require a grand jury indictment for a felony prosecution. The case was brought by a woman named Francisca Hurtado, who was charged with murder in California. She argued that the state's requirement of a grand jury indictment violated her rights under the Fifth and Fourteenth Amendments of the United States Constitution. The Supreme Court held that the Fifth Amendment did not apply to the states, and thus the state of California was not required to provide a grand jury indictment for a felony prosecution. The Court reasoned that the Fifth Amendment was intended to protect individuals from the federal government, and that the Fourteenth Amendment did not extend the protections of the Fifth Amendment to the states. The Court also held that the Fourteenth Amendment did not require the states to provide a grand jury indictment for a felony prosecution. The Court reasoned that the Fourteenth Amendment was intended to protect individuals from state action, and that the state of California was not required to provide a grand jury indictment for a felony prosecution. In conclusion, the Supreme Court held that the state of California was not required to provide a grand jury indictment for a felony prosecution. The Court reasoned that the Fifth Amendment did not apply to the states, and that the Fourteenth Amendment did not require the states to provide a grand jury indictment for a felony prosecution.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Hurtado v. People of California, arguing that the majority's decision was a misinterpretation of California law and an infringement on states' rights. He argued that under Article IV Section 2 of the Constitution, which guarantees to each state all privileges and immunities enjoyed by citizens in other states, it is up to each individual state to decide how its criminal proceedings should be conducted. In this case, he noted that California had chosen not to allow grand juries for felony prosecutions since 1850; thus any attempt by Congress or the Supreme Court to impose such a requirement would be unconstitutional interference with state authority. Furthermore, Justice Field argued that even if there were no constitutional impediment against federal intervention here, allowing grand jury indictments would still violate due process because defendants could potentially face multiple trials for one offense without being able to challenge evidence presented at earlier trials before different juries - something which is prohibited under double jeopardy laws. Finally he concluded his dissent by noting that while some may argue for greater uniformity among criminal procedures across different states as desirable from a policy perspective; ultimately it must remain within each individual state’s purview whether or not they choose certain procedural safeguards like requiring grand jury indictments prior trial

Opinion written by Justice SMatthews
Decided: Mar 03, 1884
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