Murphy v. Waterfront Commission

Murphy v. Waterfront Commission of New York Harbor
Supreme Court of the United States
Argued March 5, 1964 Decided June 15, 1964
Full case name	Murphy v. Waterfront Commission of New York Harbor
Citations	378 U.S. 52 (more) 84 S. Ct. 1594 (1964) 12 L. Ed. 2d 678
Argument	Oral argument
Case history
Prior	In re Waterfront Comm'n of N.Y. Harbor, 171 A.2d 295 (N.J. 1961); cert. denied, 368 U.S. 32 (1961); 189 A.2d 36 (N.J. 1963); cert. granted, 375 U.S. 812 (1963).
Holding
The right against self-incrimination is not precluded by the grant of immunity from prosecution under state laws, when the testimony might be incriminating under the laws of another jurisdiction.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Goldberg, joined by unanimous
Concurrence	Black
Concurrence	Harlan, joined by Clark
Concurrence	White, joined by Stewart
Laws applied
U.S. Const. amend. V, U.S. Const. amend. XIV
This case overturned a previous ruling or rulings
United States v. Murdock, 284 U.S. 389 (1931) Knapp v. Schweitzer, 357 U.S. 371 (1958)

Murphy v. Waterfront Commission of New York Harbor, 378 U.S. 52 (1964), was a United States Supreme Court case concerning the self-incrimination clause in the Fifth Amendment to the United States Constitution. The Court ruled that a state cannot compel a witness to provide testimony that may be incriminating under other State/Federal laws, even if it granted immunity under its own laws.^[1] Decided on the same day as Malloy v. Hogan (1964), the Supreme Court reconsidered its previous rulings that the Federal Government could compel witness testimony that could be incriminating under a state's laws,^[2] and states could similarly compel testimony that would be incriminating under Federal law.^[3]

Background

The Waterfront Commission of New York Harbor is a bi-state agency tasked to investigate and aid prosecution of criminal activity in the Port of New York and New Jersey. While investigating work stoppage activity suspected to be in violation of the Waterfront Commission Act, it subpoenaed petitioners asking them to testify about the striking activity under investigation.^[4] Petitioners were granted immunity from prosecution under New York and New Jersey laws pursuant to New Jersey law, but they refused to testify beyond their names and union membership status, claiming that the immunity did not protect them from federal prosecution. They were held in civil and criminal contempt by the Law Division of the New Jersey Superior Court.^[4] The criminal contempt charges were reversed on appeal to the Supreme Court of New Jersey, while the civil contempt charges were remanded for a new trial. Petitioners appealed to the United States Supreme Court, arguing that the contempt charges were in violation of the Fifth Amendment.

See also

• List of United States Supreme Court cases, volume 378

References

1. Murphy v. Waterfront Comm'n of N.Y. Harbor, 378 U.S. 52 (1964).
2. United States v. Murdock, 284 U.S. 389 (1931).
3. Knapp v. Schweitzer, 357 U.S. 371 (1958).
4. In re Waterfront Comm'n of N.Y. Harbor, 189 A.2d 36 (N.J. 1963).

Further reading

• Rydell, Thomas C. (April 1965). "Witness - Privilege against Self-Imcrimmination - Federal Officials Barred from Using Testimony Elicited under State Immunity Statute". Chicago-Kent Law Review. 42 (1): 59–63 – via Digital Commons.

External links

• Works related to Murphy v. Waterfront Commission of New York Harbor at Wikisource
• Text of Murphy v. Waterfront Comm'n of N.Y. Harbor, 378 U.S. 52 (1964) is available from: CourtListener Justia Library of Congress Oyez (oral argument audio)