Murphy v. Waterfront Comm'n of N.Y. Harbor - 378 U.S. 52, 84 S. Ct. 1594 (1964)

Rule:

The constitutional rule is that a state witness may not be compelled to give testimony which may be incriminating under federal law unless the compelled testimony and its fruits cannot be used in any manner by federal officials in connection with a criminal prosecution against him. In order to implement the constitutional rule and accommodate the interests of the state and federal governments in investigating and prosecuting crime, the federal government must be prohibited from making any such use of compelled testimony and its fruits. Once a defendant demonstrates that he has testified, under a state grant of immunity, to matters related to a federal prosecution, the federal authorities have the burden of showing that their evidence is not tainted by establishing that they had an independent, legitimate source for the disputed evidence.

Facts:

Notwithstanding the grant of immunity under the laws of New Jersey and New York, petitioners, as witnesses before the Waterfront Commission of New York Harbor, refused to answer questions on the ground that the answers might tend to incriminate them under federal law, to which the grant of immunity did not purport to extend. Petitioners were thereupon held in civil and criminal contempt of court. The New Jersey Supreme Court affirmed the civil contempt judgments, holding that a state may constitutionally compel a witness to give testimony which might be used in a federal prosecution against him. Certiorari was granted to review the decision of the state supreme court.

Issue:

May a state constitutionally compel a witness to give testimony which might be used in a federal prosecution against him?

Answer:

No.

Conclusion:

The Court held that one jurisdiction in the federal system may not, absent an immunity provision, compel a witness to give testimony which might incriminate him under the laws of another jurisdiction. According to the Court, a state witness granted immunity from prosecution under state law may not be compelled to give testimony which may incriminate him under federal law unless such testimony and its fruits cannot be used in connection with a federal prosecution against him; and such use of compelled testimony or its fruits, as distinguished from independent evidence, by the Federal Government must be proscribed. The State may thus obtain information requisite for effective law enforcement and the witness and the Federal Government were left in the same position as if the witness claimed his privilege in the absence of a state grant of immunity. With the removal of the fear of federal prosecution, the petitioners may be compelled to answer.