Boyd v. United States - 142 U.S. 450, 12 S. Ct. 292 (1892)

Rule:

On a trial for murder, evidence of other crimes, such as robberies, committed by the defendants, is inadmissible; and the error of admitting such evidence is not cured by the judge's charge that defendants were not to be convicted because of the commission of such other crimes. Moreover, however depraved in character, and however full of crime their past lives may have been, defendants are entitled to be tried upon competent evidence, and only for the offense charged.

Facts:

In the night of April 6, 1890, defendants Boyd and Standley, with Myers, came to a ferry and called to the ferryman, Martin Byrd, to come and set them over the creek. The latter protested that he did not like to do work of that kind after dark, but finally consented. He went to his house to get the key and returned with companies, each with weapons. When the ferryman was about to unlock the chain by which it was held fast, defendants told him that they did not want to cross because it was his money that they were after. Thereafter, the ferryman’s company was shot in the back by defendant Boyd. The other defendant was shot and died instantly. The firing then immediately became general. Defendant, although badly wounded, went up the creek some little distance, but since he was being followed, he was secured and carried to the ferryman’s house as a prisoner. He remained there until he was arrested by an officer on the charge of murder. On his part, defendant presented evidence that tend to show a materially different case. Defendant objected when the principal witness for the prosecution was the ferryman. They objected to him as incompetent for being convicted of the crime of larceny and sentenced to the penitentiary. However, it was shown that the witness was pardoned by the President of the United States. Thus, this pardon removed all objections to his competency as a witness. The trial court admitted evidence which was several unrelated robberies committed by defendants prior to the murder, the limited purpose of which was to show that the victim was attempting to arrest the defendants for robbery when the murder occurred. The trial court then instructed the jury that if a number of men agreed to do an act that puts human life in jeopardy, then all who entered into the enterprise were responsible for the death of the innocent person. The trial court instructed that the crime of robbery was such a crime. Defendants were then convicted of murder and were sentenced to suffer death punishment. Defendants sought review.

Issue:

Were defendants' convictions of murder and punishment of death proper?

Answer:

No.

Conclusion:

The court reversed the judgment of the trial court. The court held that the evidence of the robberies was inadmissible for the identification of the defendants or for any other purpose. The court reasoned that whether the defendants committed the robbery or not, these were matters that were wholly apart from the inquiry as to the murder charge. These robberies were collateral of the murder trial. Also, no notice was given in the indictment concerning the introduction of evidence that concerned the robberies. They afforded no legal presumption or inference as to the particular crime charged. The court ruled that those robberies may have been committed by the defendants, yet they may have been innocent of the murder. Clearly, proof of them only tended to prejudice the defendants with the jurors, in order to draw their minds away from the real issue and to produce the impression that defendants were nothing but wretches whose lives were of no value to the community, and who were not entitled to the full benefit of the rules prescribed by law for the trial of human beings charged with crime involving the punishment of death. It was, thus, clear that defendants were prejudiced as a result. To conclude, the court was of the view that however depraved in character, and however full of crime their past lives may have been, defendants were entitled to be tried upon competent evidence, and only for the offense charged. Therefore, the judgment was reversed and the case was remanded with direction to grant a new trial.