Young v. United States Ex Rel. Vuitton Et Fils S.A. case brief summary
481 U.S. 787 (1987)
SYNOPSIS:
Petitioners sought review of the judgment of the United States Court of Appeals for the Second Circuit affirming the convictions of petitioners for criminal contempt pursuant to 18 U.S.C.S. § 401(3) for violation of an injunction prohibiting petitioners' infringement of respondent's trademark.
OVERVIEW: Respondent corporation alleged petitioners were manufacturing imitations of corporation's leather goods. A settlement was reached whereby petitioners were enjoined from further reproductions of corporation's products. When violations of this order were discovered, petitioners were prosecuted and found guilty of criminal contempt. The appellate court affirmed petitioners' convictions. Petitioners appealed asserting the district court erred in appointing corporation's attorneys as special prosecutors as such violated petitioners' right to be prosecuted by an impartial prosecutor.
HOLDING:
The Court held that because private attorneys appointed to prosecute a criminal contempt action represented the United States and not the party that was the beneficiary of the court order allegedly violated, the private attorney should be as disinterested as a public prosecutor who undertook such a prosecution.
ANALYSIS:
Further, the harmless error standard of review was not the proper standard to review the appointment of an interested prosecutor in this instance. Therefore, appointment of the corporation's attorneys to conduct the contempt prosecution was improper, and the judgment was reversed.
OUTCOME: Petitioners' convictions were reversed where the appointment of respondent's attorneys to conduct contempt hearings against petitioners was improper.
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481 U.S. 787 (1987)
SYNOPSIS:
Petitioners sought review of the judgment of the United States Court of Appeals for the Second Circuit affirming the convictions of petitioners for criminal contempt pursuant to 18 U.S.C.S. § 401(3) for violation of an injunction prohibiting petitioners' infringement of respondent's trademark.
OVERVIEW: Respondent corporation alleged petitioners were manufacturing imitations of corporation's leather goods. A settlement was reached whereby petitioners were enjoined from further reproductions of corporation's products. When violations of this order were discovered, petitioners were prosecuted and found guilty of criminal contempt. The appellate court affirmed petitioners' convictions. Petitioners appealed asserting the district court erred in appointing corporation's attorneys as special prosecutors as such violated petitioners' right to be prosecuted by an impartial prosecutor.
HOLDING:
The Court held that because private attorneys appointed to prosecute a criminal contempt action represented the United States and not the party that was the beneficiary of the court order allegedly violated, the private attorney should be as disinterested as a public prosecutor who undertook such a prosecution.
ANALYSIS:
Further, the harmless error standard of review was not the proper standard to review the appointment of an interested prosecutor in this instance. Therefore, appointment of the corporation's attorneys to conduct the contempt prosecution was improper, and the judgment was reversed.
OUTCOME: Petitioners' convictions were reversed where the appointment of respondent's attorneys to conduct contempt hearings against petitioners was improper.
---
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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