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United States v. Wilson

• 1891 • 144 U.S. 24 • Fuller Court
In the United States v. Wilson case of 1891, the Supreme Court ruled on a matter concerning double jeopardy. The defendant, Wilson, had been convicted for murder and sentenced to death in Pennsylvania but was pardoned by President Andrew Johnson. However, he refused to accept this pardon unless it could be done so without him admitting guilt. Later on, when charged with another crime related to the same incident (robbery), he invoked his right against double jeopardy - arguing that since he had...Open Case
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Chief Fuller Court
Term: 1891
Docket: 1157
144 U.S. 24
12 S. Ct. 539
36 L. Ed. 332
1892 U.S. LEXIS 2050
Argued: Jan 26, 1892

United States v. Wilson

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Opinion Summary
AI Abstract

In the United States v. Wilson case of 1891, the Supreme Court ruled on a matter concerning double jeopardy. The defendant, Wilson, had been convicted for murder and sentenced to death in Pennsylvania but was pardoned by President Andrew Johnson. However, he refused to accept this pardon unless it could be done so without him admitting guilt. Later on, when charged with another crime related to the same incident (robbery), he invoked his right against double jeopardy - arguing that since he had already been tried and pardoned for murder arising from the same facts as those underlying the robbery charge; trying him again would constitute being prosecuted twice for essentially one offense. The court held that a presidential pardon must be accepted by an individual before it can take effect because its delivery is not complete without acceptance. It also clarified that a pardon carries an 'imputation of guilt', acceptance therefore implies confession of it which explains why some might refuse them. Furthermore, they stated that each separate crime constitutes its own offense regardless if they arise from one transaction or circumstance; hence there's no violation of protection against double jeopardy even though both charges were based upon similar evidence.

Dissent Summary
AI Abstract

In the dissenting opinion for United States v. Wilson, Justice Brewer argued that a pardon by the President does not automatically restore all rights and privileges to an individual convicted of a crime unless it is accepted by the person pardoned. He contended that acceptance was necessary because a pardon carried an imputation of guilt and accepting it implied confession of guilt. Therefore, if someone refused to accept their presidential pardon, they could still be tried for their crimes as though no such offer had been made. This view differed from the majority's interpretation which held that once issued, a presidential pardon absolves individuals from any further punishment regardless of whether or not they choose to accept it.

Opinion written by Justice LQLamar
Decided: Mar 14, 1892
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