Brown v. United States (1958)
- Docket
- 4
- Decided
- 1958-01-01
- Category
- General
Summary
Question: Did the district court judge abuse his discretion when he sentenced Brown to 15 months in prison? Conclusion: No. Justice Potter Stewart, writing for a 5-4 majority, affirmed the conviction. The Supreme Court held that the FMCA clearly provided Brown with immunity from prosecution based on his testimony. Because he could not possibly incriminate himself, he could not invoke the Fifth Amendment. There was no statutory cap on sentencing, so 15 months was not an abuse of discretion. Chief Justice Earl Warren dissented, arguing that the district judge denied Brown due process by following Federal Rule of Civil Procedure 49(a) instead of 49(b). Under 49(b) Brown would be sentenced to prison until he agreed to answer the questions instead of a fixed 15 month sentence. Justice Hugo L. Black, Justice William O. Douglas, and Justice William J. Brennan, Jr. joined the dissent.