Weems V. United States - Decision

Decision

Justice McKenna delivered the opinion of the court, joined by Chief Justice Fuller and Justices Harlan, Day, and Moody. Justice Lurton, who had not been a member of the Court when the case had been argued, did not take part in the decision.

The Court determined that the plaintiff's first assignment of error was incorrect. The opinion cited acts of U.S. Congress and the Philippine Commission as indicating that their respective governments, while politically connected in important ways, were separate and distinct entities. The Court specifically cites the Philippine Criminal Code of Procedure, which, in part, requires that charges be, "in such form as to enable a person of common understanding to know what is intended," and that no trial, judgment, or other proceeding can, "be affected, by reason of a defect in matter of form which does not tend to prejudice a substantial right of the defendant upon the merits."

Addressing the second and third points of the plaintiff's argument simultaneously, the Court determined that the sentence of 15 years in prison was unconstitutionally cruel and unusual. In particular, the Court noted that the conditions of incarceration specifically included being chained from wrist to ankle and compelled to work at "hard and painful labor." Citing a line of cases related to 8th Amendment concerns, the Court demonstrated also that such a severe penalty for so relatively minor a crime was impermissible. In fact, the Court stated that even if the least severe form of punishment statutorily allowed for this crime had been ordered, this would have been "repugnant to the Bill of Rights." Stating that the fault was in the law itself, and seeing no other applicable law under which Weems could be sentenced, the Court ordered the judgment reversed, with directions to dismiss the charges entirely.