United States V. Moreland - Facts and History

Facts and History

The dissenting opinion written by Justice Louis Brandeis offers a succinct account of the facts that led up to this case:

On January 18, 1921, an information, under the Act of March 23, 1906, c. 1131, 34 Stat. 86, was filed against Moreland in the juvenile court of the District of Columbia for willfully neglecting to provide support for his minor children-girls aged 8 and 13. He was tried by a jury and found guilty.

(An information is defined as “a formal accusation of a crime made by a public officer rather than by grand jury indictment.”)

The statute described by Justice Brandeis (also referred to as the Act of March 23, 1906 or the Act) suggests the punishment of

‘a fine of not more than $500 or by imprisonment in the workhouse of the District of Columbia at hard labor for not more than twelve months or by both such fine and imprisonment.’

Mr. Moreland underwent a jury trial and was found guilty of failing to provide proper child support; the Supreme Court found no issue with the proceedings themselves. The juvenile court suspended sentence and gave him a chance to make these obligatory payments. After a month of failing to do so, “Moreland was sentenced on April 19, 1921, to be committed to the workhouse at hard labor for 6 months.”

Moreland objected to the sentence, claiming the offense he had been charged with amounted to an infamous crime because the Act of March 23, 1908 included hard labor as a potential punishment; the Fifth Amendment of the U.S. Constitution would therefore apply, as would its ban on individuals being held to answer for infamous crimes without indictment or presentment by a grand jury. The juvenile court overruled his claim. Moreland appealed.

The trial originated in the D.C. court system, so the appeal went directly to the D.C. Circuit Court of Appeals, which reversed the juvenile court’s decision and directed that the complaint be dismissed, freeing Moreland. The Court of Appeals relied upon the findings of Wong Wing in making its determination that Moreland’s claim was valid, and therefore found the Act of March 23, 1908 to be unconstitutional. Writ of certiorari was filed and granted by the Supreme Court.