Holt v. United States
218 U.S. 245 (1910)
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Rule of Law:
The Fifth Amendment's privilege against self-incrimination protects an accused person only from being compelled to provide testimonial or communicative evidence, not from being required to display their physical characteristics for use as real or physical evidence.
Facts:
- Holt was accused of committing a murder on the Fort Worden Military Reservation.
- The murder of Henry E. Johnson was allegedly committed with an iron bar.
- A key piece of evidence in the case was a blouse.
- A witness was prepared to testify that the blouse belonged to Holt.
- To confirm this, Holt was compelled to put on the blouse.
- The blouse fitted Holt, and the prosecution sought to introduce this fact as evidence of his guilt.
Procedural Posture:
- Holt was indicted for murder in the U.S. Circuit Court.
- Holt's counsel moved for leave to withdraw the plea of 'Not Guilty' to interpose a plea in abatement, which the trial court denied.
- During jury selection, a challenge for cause to a potential juror was overruled by the court.
- The case was tried before a jury, which returned a verdict of guilty without capital punishment.
- The trial court sentenced Holt to life imprisonment.
- Holt then brought a writ of error to the Supreme Court of the United States to review the judgment.
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Issue:
Does compelling an accused person to put on a piece of clothing to determine if it fits, for use as evidence against them, violate their Fifth Amendment privilege against self-incrimination?
Opinions:
Majority - Mr. Justice Holmes
No. Compelling an accused to model a piece of clothing does not violate the Fifth Amendment's privilege against self-incrimination. The Court reasoned that the prohibition against compelling a person to be a witness against themselves is a prohibition on the use of physical or moral compulsion to extort communications, not an exclusion of the person's body as evidence when it may be material. The privilege protects against testimonial compulsion, which reveals the contents of one's mind, rather than the use of physical characteristics. The Court analogized this to a jury looking at a prisoner and comparing their features to a photograph, stating that the objection in principle would forbid even that. Therefore, even if the order to put on the blouse was compelling, the resulting evidence of the fit is competent and admissible.
Analysis:
This case establishes the critical distinction between testimonial evidence, which is protected by the Fifth Amendment, and physical evidence, which is not. It significantly clarified that the privilege against self-incrimination is limited to communicative acts. This precedent paved the way for courts to uphold the constitutionality of compelling suspects to participate in police lineups, provide fingerprints, submit to blood tests, or give handwriting and voice exemplars. By narrowing the scope of the privilege to the 'testimonial or communicative,' Holt v. United States ensured that law enforcement could utilize a suspect's own physical attributes as a source of evidence in criminal investigations.
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