Murphy v. Waterfront Comm.
Facts
Petitioners were subpoenaed to testify before the Waterfront Commission of New York Harbor about a work stoppage at the Hoboken piers. They refused to answer certain questions on the ground that their answers might incriminate them, and they were then granted immunity from prosecution under New Jersey and New York law. Petitioners still refused to answer because their answers might incriminate them under federal law, which the immunity grant did not cover. They were then held in contempt.
Issue
Whether one jurisdiction in the federal system may compel a witness, after granting immunity only from prosecution under its own laws, to give testimony that may incriminate the witness under the criminal laws of another jurisdiction. Relatedly, whether testimony so compelled by a State may be used by federal officials in a criminal prosecution.
Rule
The constitutional privilege against self-incrimination protects a state witness against incrimination under federal as well as state law, and protects a federal witness against incrimination under state as well as federal law. A state witness may not be compelled to give testimony that may incriminate him under federal law unless the compelled testimony and its fruits cannot be used in any manner by federal officials in connection with a criminal prosecution against him; once the defendant shows he testified under a state grant of immunity to matters related to the federal prosecution, federal authorities bear the burden of showing an independent, legitimate source for the evidence.
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After receiving the state immunity grant, may Ohio compel Nora to answer over her Fifth Amendment objection?