James A. Simmons v. United States Docket No. 1891-1296 142 U.S. 148, 35 L.Ed. 968, 12 S.Ct. 171 ( 1891) Argued December 11, 1891. Decided December 21, 1891.
One of the many questions raised by the conflict between a free press and a fair trial is who has the legal authority to decide when a jury has been so strongly influenced by information gained from outside the trial that an unprejudiced verdict cannot be achieved. Another is what kind of information is so important that exposure to it would prevent a jury from rendering an unprejudiced verdict. These two questions are addressed in this case.
The Court ruled as early as Mima Queen v. Hepburn ( 1813) that defendants do not have a right to jurors who are prejudiced in their favor because "it was desirable to submit the case to those who felt no bias either way, and therefore the court exercised a sound discretion in not permitting him [a juror] to be sworn" (297). The nine justices supported a trial court's authority and "sound discretion" in dismissing a juror who said he would find it difficult to rule against a slave like Mima Queen since he was against slavery. In Perez v. U.S. ( 1824) the Court asserted that trial judges who exercise "sound discretion" possess "the authority to discharge a jury from giving any verdict, whenever in their opinion . . . there is a manifest necessity for the act, or the ends of public justice would otherwise be defeated" (580). Here the Court extends the authority of a trial court to include discharging a jury that a judge who exercised "sound discretion" feels has been exposed sufficiently to evidence outside a trial so that it cannot render an unprejudiced verdict.
Peter J. Classen, who was the president of Sixth National Bank of the City of New York, was convicted in late 1890 of "converting to his own use"