Coffin v. United States

Coffin v. United States, 156 U.S. 432 (1895), was an appellate case before the United States Supreme Court in 1895 which established the presumption of innocence of persons accused of crimes.

Coffin v. United States
Argued December 6 – December 7, 1894
Decided March 4, 1895
Full case nameCoffin, et al. v. United States
Citations156 U.S. 432 (more)
15 S. Ct. 394; 39 L. Ed. 481
Holding
It is the duty of the judge, in all jurisdictions, when requested, and in some when not requested, to explain the presumption of innocence to the jury in his charge. The usual formula in which this doctrine is expressed is that every man is presumed to be innocent until his guilt is proved beyond a reasonable doubt.
Court membership
Chief Justice
Melville Fuller
Associate Justices
Stephen J. Field · John M. Harlan
Horace Gray · David J. Brewer
Henry B. Brown · George Shiras Jr.
Howell E. Jackson · Edward D. White
Case opinion
MajorityWhite, joined by unanimous

F. A. Coffin and Percival B. Coffin, plaintiffs in error, and A. S. Reed had been charged with aiding and abetting the former president of the Indianapolis National Bank, Theodore P. Haughey, in misdemeanor bank fraud between January 1, 1891, and July 26, 1893.

It is a complex case with a 50-count indictment. But the most interesting aspect is commentary by the Court regarding presumption of innocence:

The principle that there is a presumption of innocence in favor of the accused is the undoubted law, axiomatic and elementary, and its enforcement lies at the foundation of the administration of our criminal law ... Concluding, then, that the presumption of innocence is evidence in favor of the accused, introduced by the law in his behalf, let us consider what is 'reasonable doubt.' It is, of necessity, the condition of mind produced by the proof resulting from the evidence in the cause. It is the result of the proof, not the proof itself, whereas the presumption of innocence is one of the instruments of proof, going to bring about the proof from which reasonable doubt arises; thus one is a cause, the other an effect. To say that the one is the equivalent of the other is therefore to say that legal evidence can be excluded from the jury, and that such exclusion may be cured by instructing them correctly in regard to the method by which they are required to reach their conclusion upon the proof actually before them; in other words, that the exclusion of an important element of proof can be justified by correctly instructing as to the proof admitted. The evolution of the principle of the presumption of innocence, and its resultant, the doctrine of reasonable doubt, make more apparent the correctness of these views, and indicate the necessity of enforcing the one in order that the other may continue to exist.

In the decision, the Court then goes on to detail the complete legal history of presumed innocence.

See also

Further reading
  • Helgeson, Vicki S.; Shaver, Kelly G. (1990). "Presumption of Innocence: Congruence Bias Induced and Overcome". Journal of Applied Social Psychology. 20 (4): 276–302. doi:10.1111/j.1559-1816.1990.tb00412.x.
  • Volokh, Alexander (1997). "n Guilty Men". University of Pennsylvania Law Review. The University of Pennsylvania Law Review. 146 (1): 173–216. doi:10.2307/3312707. JSTOR 3312707. Archived from the original on 2004-02-07.
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