Murphy v. Waterfront Commission of New York
"Murphy v. Waterfront Commission of New York" is a significant Supreme Court case that addresses the issue of self-incrimination and the use of evidence obtained under compulsion. The case culminated in a unanimous decision authored by Justice Arthur J. Goldberg, which established that incriminating evidence acquired by one governmental entity cannot be utilized by another in criminal prosecutions. This ruling overruled a previous decision in Feldman v. United States and aligned closely with the principles established in Malloy v. Hogan, which extended the Fifth Amendment's protections against self-incrimination to the states. The Court emphasized that while the right against self-incrimination is not absolute, any grants of use immunity must be as comprehensive as the protections provided by the Fifth Amendment. This decision has since been refined by later cases, notably Kastigar v. United States. Overall, "Murphy v. Waterfront Commission" is pivotal in shaping the legal landscape surrounding self-incrimination and the limits of governmental authority in criminal proceedings.
Murphy v. Waterfront Commission of New York
Date: June 15, 1964
Citation: 378 U.S. 52
Issue: Immunity against self-incrimination
Significance: The Supreme Court prohibited federal prosectors from using incriminating evidence compelled by the state, citing the privilege against self-incrimination.
Justice Arthur J. Goldberg wrote the unanimous opinion for the Supreme Court, holding that incriminating evidence obtained under compulsion by one level of government may not be used by another in criminal prosecutions. This decision overruled Feldman v. United States (1944) and was handed down on the same day as Malloy v. Hogan (1964), which had applied the Fifth Amendment’s protection against self-incrimination to the states. The logic of Malloy is evident in this decision. The protection against self-incrimination is not absolute, but grants of use immunity must be as broad as the original protection in the Fifth Amendment. This decision was limited by the Court’s ruling in Kastigar v. United States (1972).
