Logan v. United States
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The confirmed treatments are listed below: a later statute changed the rule on where an indictment must be returned, and Supreme Court decisions rejected Logan's approach to fixed common law evidence rules, postconspiracy acts, and death penalty juror exclusions. In re Marino (7385739), United States v. Salisbury (8596262), and several later opinions report what other Supreme Court decisions did to Logan. The entries below cite those decisions directly. The texts of Bell v. Maryland (106879), Sugarman v. Dougall (108859), and Ex parte Queen (2385135) do not cite Logan, so they support no treatment of it.
45 later cases cite Logan v. United States; 45 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Logan v. United States?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Abrogated
-
The Supreme Court rejected Logan's apparent requirement that federal criminal trials use witness competency rules frozen at a specified point in state history.
Funk v. United States · Supreme Court of the United States · filed
The Logan case in part rejected that view and held that the controlling rule was that of the common law in force at the time of the admission of the state in which the particular trial was had. Taking the two cases together, it is plain enough that the ultimate doctrine announced is that in the taking of testimony in criminal cases, the federal courts are bound by the rules of the common law as they existed at a definitely specified time in the respective states, unless Congress has otherwise provided. With the conclusion that the controlling rule is that of the common law, the Benson case and the Rosen case do not conflict; but both cases reject the notion, which the two earlier ones seem to accept, that the courts, in the face of greatly changed conditions, are still chained to the ancient formulae and are powerless to declare and enforce modifications deemed to have been wrought in the common law itself by force of these changed conditions.
Read the full opinion on CourtListener → -
The Supreme Court rejected Logan's approval of excluding prospective capital jurors simply because they expressed conscientious scruples about the death penalty.
Witherspoon v. Illinois · Supreme Court of the United States · filed
We have considered the suggestion, advanced in an amicus curiae brief filed by 27 States on behalf of Illinois, that we should “give prospective application only to any new constitutional ruling in this area,” particularly since a dictum in an 1892 decision of this Court approved the' practice of challenging for cause those jurors who expressed “conscientious scruples in regard to the infliction of the death penalty for crime.” Logan v. United States, 144 U. S. 263, 298. But we think it clear, Logan notwithstanding, that the jury-selection standards employed here necessarily undermined “the very integrity of the . . . process” that decided the petitioner’s fate
Read the full opinion on CourtListener →
Superseded by statute
-
A later federal statute required indictments to be returned in the division where the crime occurred, replacing the practice that Logan had permitted.
United States v. Chennault · E.D. La. · filed
Under the wording of the former statute (Act Aug. 13, 1888, c. 869, 25 Stat. 438), creating the Baton Rouge division, and the decision in Logan v. United States, 144 U. S. 263, 12 Sup. Ct. 617, 36 L. Ed. 429, there could be no doubt as to the validity of indictments so found and transferred, and the question was never heretofore raised, although the custom continued after the adoption of the Judicial Code. Section 53, Judicial Code, however, makes a material change in the law.
Read the full opinion on CourtListener →
Limited
-
The Supreme Court declined to apply Logan's suggestion that acts after a conspiracy ended, like later declarations, were inadmissible against other conspirators.
Lutwak v. United States · Supreme Court of the United States · filed
True, there is dictum in Logan v. United States, supra, at 309, frequently repeated, which would limit the admissibility of both acts and declarations to the person performing them. This statement of the rule overlooks the fact that the objection to the declarations is that they are hearsay. This reason is not applicable to acts which are not intended to be a means of expression. The acts, being relevant to prove the conspiracy, were admissible, even though they might have occurred after the conspiracy ended.
Read the full opinion on CourtListener →
Does this case still carry your argument?
Describe your facts. Ezel reads Logan v. United States and the cases that treated it, then tells you whether it still holds for your situation, with citations.
Opens in Ezel Pro.
- Checks the law as it stands today, not only this page
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace