Rivera v United States

Read the analysis of a US Court judgement to learn how the foreign court emphasized on procedure established by law so as to deliver justice, it further discussed the role of circumstantial evidence in deciding a case.
CITATION 
COURTUnited States Court
JUDGES/CORAM 
DATE OF JUDGEMENT 

Introduction

This is a foreign judgment on the matter of conspiracy dealt by circuit court of the USA. The case also dealt with significance of hearsay evidence.

Facts

The facts of the case are as follows: The case is before the Circuit Court of Appeal brought forward by the appellant Faustino Enrique Rivera and Ramon Monchin aggrieved by the judgment of the District Judge; who had held them liable under section 37 of Criminal Code of the United States.

The initial facts can be summed up as – In April 1930 Faustino Enrique Rivera and Ramon Monchin, did unlawfully, wilfully and knowingly conspire, combine, confederate and agree together, with each other, and with other unknown persons, to fraudulently and knowingly facilitate the transportation of certain merchandise which had been imported in the United States contrary to law and the appellants were aware of such unlawful nature of the transported merchandise upon that the duty on said merchandise as required by the Tariff Act of 1922 was not paid.

The merchandise consisted of 93 sacks of Holstein Pilsener Beer and its transportation was facilitated in Brockway truck, which was loaded with the said merchandise, to wit, 93 sacks of Holstein Pilsener Beer, and the said truck was escorted by the appellants seated in a Dodge Victory Sedan automobile. Later upon facing the authorities the appellants and several other unknown persons came out with guns to prevent search and seizure of the merchandise and the truck.

The District Court rejected the contention of the then defendants claiming that there is no evidence of conspiracy and involvement of the defendants thus the case shall be dismissed. Eventually the case came before this Court.

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Issues

The main issues in the case were:

  1. Whether the State successfully proved the involvement of the appellant in an unlawful act or activity or not?
  2. Whether the alleged conspiracy show sufficient facts to make it an offence under any statute of the United States or not?

Summary of court decision and judgment

The chain of circumstances in the case do not require a finding, as the only reasonable hypothesis, that the defendants knew the origin of the contents of the truck or its nature, except that it was contraband, which does not constitute the offense with which they are charged.

The circumstantial evidence in the case not being sufficient to warrant a verdict of guilty, the court below should have granted the motion to direct a verdict of not guilty. The judgment of the District Court is reversed, the verdict was set aside.

Analysis

Section 37 of the Criminal Code provides as follows: “If two or more persons conspire either to commit any offense against the United States, or to defraud the United States in any manner or for any purpose, and one or more of such parties do any act to effect the object of the conspiracy, each of the parties to such conspiracy shall be fined not more than $10,000, or imprisoned not more than two years, or both.”

The object of the conspiracy was to “fraudulently and knowingly facilitate the transportation of certain merchandise which had been imported into the United States contrary to law,” which comes under the inhibition of 19 USCA § 497 (42 Stat. 982, § 593 (b), as follows: “If any person fraudulently or knowingly imports or brings into the United States, or assists in so doing, any merchandise, contrary to law, or receives, conceals, buys, sells, or in any manner facilitates the transportation, concealment, or sale of such merchandise after importation, knowing the same to have been imported or brought into the United States contrary to law, such merchandise shall be forfeited and the offender shall be fined in any sum not exceeding $5,000 nor less than $50, or be imprisoned for any time not exceeding two years, or both. Whenever, on trial for a violation of this section, the defendant is shown to have or to have had possession of such goods, such possession shall be deemed evidence sufficient to authorize conviction, unless the defendant shall explain the possession to the satisfaction of the jury.”

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Important case mentioned in this case was of Williamson vs. United States[1]. The main point upon which the case was decided was that the evidence relied upon by the prosecution was hearsay or circumstantial which couldn’t be able to chain in a manner which would prove the guilt of the accused beyond reasonable doubt. Thus, the decision was in favour of the appellants in the present case.

Conclusion

It is important to note that the procedure established by law is to be followed in the manner in which it is prescribed to be to deliver justice. Sometimes due to this procedure few cases might be adjudged erroneously but that shouldn’t result in resistance from the authorities/judges/public to not follow the law albeit changes are to be made to find and cover the loopholes and also alter to incorporate budding issues of new centuries.


[1]  207 U.S. 425, 447, 28 S. Ct. 163, 52 L. Ed. 278