Monday, December 23, 2013

Miller v. United States case brief

Miller v. United States case brief summary
471 U.S. 130 (1985)

Petitioner United States sought review of the decision of the United States Court of Appeals for the Ninth Circuit, which vacated respondent's conviction for mail fraud because the variance between the indictment and the crimes he was convicted of violated the grand jury clause of U.S. Constitutional Amendment V.

A grand jury returned an indictment that charged respondent with three counts of mail fraud in violation of 18 U.S.C.S. § 1341. After petitioner United States moved to dismiss the third count, respondent was convicted of the remaining two. Respondent appealed, asserting that there was a fatal variance between what was charged in the indictment and that which petitioner proved at trial.


  • The Supreme Court reversed the decision of the appellate court, which vacated respondent's conviction and explicitly rejected the proposition that an amendment to drop from an indictment those allegations that were unnecessary to an offense was unconstitutional. 
  • The Court held that respondent's indictment properly alleged violations and it fully and clearly set forth a number of ways in which the acts alleged constituted violations. 
  • The Court stated that the facts proved at trial clearly conformed to one of the theories of the offense contained within the indictment. 
  • The Court held that there was no showing that the variance prejudiced the fairness of respondent's trial in any way.

The Supreme Court reversed the decision of the appellate court vacating respondent's conviction because respondent was tried on an indictment that clearly set out the offense for which he was ultimately convicted and respondent did not show any compromise of his right to be tried only on offenses for which a grand jury had returned an indictment.

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