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Logan v. United States

Supreme Court of the United States · 1892 · Constitutional Law

Constitutional LawRev. Stat. § 5508federal custodyrights secured by Constitution or laws of the United Statesconspiracynecessary and properfederal supremacyprotection of federal prisoners

Facts

The defendants were convicted of conspiring to injure and oppress citizens of the United States in the exercise of the right to be secure from assault and unlawful violence while in the custody of a United States marshal under lawful federal commitment awaiting trial on a federal offense. The prisoners were being held by a deputy marshal under writs of commitment issued by a commissioner of the Circuit Court in default of bail. The evidence tended to show that the conspirators attacked the prisoners, killed two of them, and dispersed after the attack. Some evidence also suggested that the deputy marshal and assistants failed to protect the prisoners and may have been in collusion with the conspirators.

Issue

Whether a citizen held in the lawful custody of a United States marshal under federal commitment has a right, secured by the Constitution or laws of the United States, to protection against lawless violence, so that a conspiracy to injure or oppress him in that right is punishable under Rev. Stat. § 5508. The case also presented whether the convictions could stand in light of certain trial errors, including admission of post-conspiracy statements and failure to furnish a statutory witness list in a capital case.

Rule

Every right created by, arising under, or dependent upon the Constitution or laws of the United States may be protected and enforced by Congress by appropriate means. Because the United States has the power and duty to arrest, commit, and hold federal prisoners in safe custody, persons lawfully held in exclusive federal custody have a corresponding right, secured by the Constitution and laws of the United States, to protection against lawless violence; conspiracies to injure or oppress them in that right fall within Rev. Stat. § 5508. In conspiracy cases, only acts and declarations of conspirators made while the conspiracy is pending and in furtherance of its object are admissible against others.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Denver, Noah Bennett was arrested on a federal counterfeiting complaint and, after failing to post bond, was held under a valid federal commitment in the custody of a deputy marshal. A group of private residents planned to beat him while he was being kept in a temporary holding site arranged by the marshal before his federal trial.

If the group is charged with conspiring to injure Noah in the exercise of a right secured by federal law, which is the strongest argument that the charge is valid?

Explanation. The majority held that every right created by, arising under, or dependent on the Constitution or laws of the United States may be protected by Congress. A person lawfully held in exclusive federal custody has a corresponding federally secured right to protection from lawless violence, because the United States has both the power and duty to hold him safely. The other choices overstate federal power by treating all private violence as federally punishable or relying on rights the Court said were not generally created by the Constitution.