Saturday, November 2, 2013

Bram v. United States case brief

Bram v. United States case brief summary
168 U.S. 532 (1897)

Defendant petitioned for a writ of error from the judgment of the Circuit Court of the United States for the District of Massachusetts, which affirmed defendant's conviction for murder.


  • Defendant was accused of murdering a ship's captain and others while they slept aboard a ship en route to the United States. 
  • Based solely on a co-suspect's claim that he saw defendant commit the crime, defendant was arrested. 
  • At trial, a detective who had questioned defendant was permitted to testify about defendant's statements. 
  • Defendant sought a writ of error, and the Court reversed the conviction on the ground that defendant's confession made to the detective was not voluntary, and, therefore, was improperly admitted. 
  • Defendant was in custody when the detective, in an official capacity, directed the police authorities to bring defendant as a prisoner to a private office where defendant was stripped and searched. 
  • Defendant understood that he was a prisoner and obeyed every order and direction that the detective gave. 
  • When confronted with his co-suspect's accusation, defendant feared that if he remained silent, it would be considered an admission of guilt. 
  • Thus, the facts, when taken together, were sufficient to warrant the inference that defendant was compelled to make a statement. 
  • As such, the statement was not voluntary and a new trial was necessary.


The Court reversed defendant's conviction for murder and ordered a new trial because the trial court erred in admitting testimony of a detective regarding defendant's involuntarily-made statements about his actions at the time of the murder.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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