Sparf v. United States
| Sparf v. United States | |
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| Submitted March 5, 1894 Decided January 21, 1895 |
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| Full case name | Sparf and Hansen v. United States |
| Citations | 156 U.S. 51 (more)
15 S. Ct. 273; 39 L. Ed. 343; 1895 U.S. LEXIS 2120
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| Prior history | Error to the Circuit Court of the United States for the Northern District of California |
| Court membership | |
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| Case opinions | |
| Majority | Harlan, joined by Fuller, Field, White |
| Concurrence | Jackson |
| Dissent | Brewer, joined by Brown |
| Dissent | Gray, joined by Shiras |
Sparf v. United States, 156 U.S. 51 (1895), or Sparf and Hansen v. United States, was a United States Supreme Court case testing the admissibility of confessions by multiple defendants accused of the same crime, and the responsibility of juries.
On the night of January 13, 1884, on a voyage to Tahiti, the second mate, a man called Fitzgerald, of the Hesper was found to be missing. It was believed that he had been killed and his body thrown overboard. The ship's captain, Sodergren, suspected three men, the crew members St. Clair, Hansen, and Sparf, of being participants in the murder. Sodergren kept the three suspects in holding until they arrived in Tahiti, where they were taken ashore by the United States consul at that island and were subsequently sent, with others, to San Francisco, on the vessel Tropic Bird.
The court issued its decision on January 21, 1895 by a 5-4 vote, with Justice Harlan giving the majority opinion.
The court held that if one of two persons, accused of having together committed the crime of murder, makes a voluntary confession in the presence of the other, without threat or coercion, the confession is admissible in evidence against both. However, declarations of one accomplice after the killing made in the absence of the other implicating the guilt of both are admissible in evidence only against the one making the declarations, not against the other.
Sparf v. United States clarified several questions relating to the duty of federal criminal juries, and of federal courts when instructing them.
Sparf remains the last direct opinion of the Court on jury nullification. While it does not prohibit juries from disputing the law in a case, it denies them any right to do so.
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