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''Cramer v. United States'', 325 U.S. 1 (1945), was a case in which the Supreme Court of the United States reviewed the conviction of Anthony Cramer, a
Anthony Cramer, a German-born mechanic, had associated with two Germans, Werner Thiel and Edward Kerling, one of whom he had prior business dealings with. The two were later found to be in the United States for the purpose of
German
German(s) may refer to:
* Germany (of or related to)
** Germania (historical use)
* Germans, citizens of Germany, people of German ancestry, or native speakers of the German language
** For citizens of Germany, see also German nationality law
**Ge ...
-born naturalized citizen, for treason
Treason is the crime of attacking a state authority to which one owes allegiance. This typically includes acts such as participating in a war against one's native country, attempting to overthrow its government, spying on its military, its diplo ...
.
Background
Anthony Cramer, a German-born mechanic, had associated with two Germans, Werner Thiel and Edward Kerling, one of whom he had prior business dealings with. The two were later found to be in the United States for the purpose of sabotage
Sabotage is a deliberate action aimed at weakening a polity, effort, or organization through subversion, obstruction, disruption, or destruction. One who engages in sabotage is a ''saboteur''. Saboteurs typically try to conceal their identitie ...
, as part of Operation Pastorius
Operation Pastorius was a failed German intelligence plan for sabotage inside the United States during World War II. The operation was staged in June, 1942 and was to be directed against strategic American economic targets. The operation was n ...
(see '' Ex parte Quirin''). In the aftermath of the failure of that operation, Cramer was also arrested and, in 1942, convicted on the basis of this association. Judge Henry W. Goddard set his prison term at 45 years, along with a fine of $10,000.
Cramer appealed his conviction to the Court of Appeals for the Second Circuit
The United States Court of Appeals for the Second Circuit (in case citations, 2d Cir.) is one of the thirteen United States Courts of Appeals. Its territory comprises the states of Connecticut, New York and Vermont. The court has appellate juris ...
, where his conviction was upheld.
Appealing to the court of last resort, the Supreme Court, Cramer was granted certiorari on November 8, 1943.
The case was originally argued on March 9, 1944; reargued on November 6, 1944; and finally decided on April 23, 1945.
Before the Supreme Court, Harold Medina
Harold Raymond Medina (February 16, 1888 – March 14, 1990) was a United States circuit judge of the United States Court of Appeals for the Second Circuit and previously was a United States district judge of the United States District Court for ...
, a future Federal judge, appeared for Cramer, while Solicitor General Charles Fahy defended the actions of the government.
Opinion of the Court
The Court decided five-to-four to overturn thejury
A jury is a sworn body of people (jurors) convened to hear evidence and render an impartial verdict (a finding of fact on a question) officially submitted to them by a court, or to set a penalty or judgment.
Juries developed in England du ...
verdict. Writing for the majority, Justice Robert H. Jackson said that the Constitution
A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of entity and commonly determine how that entity is to be governed.
When these princ ...
is clear in its definition of treason, limited to the waging of war
War is an intense armed conflict between states, governments, societies, or paramilitary groups such as mercenaries, insurgents, and militias. It is generally characterized by extreme violence, destruction, and mortality, using regular o ...
, or giving material assistance to an enemy. The prosecution and its witnesses could demonstrate only an association and not that Cramer had given "Aid and Comfort," as defined in Article Three. Jackson wrote that the jury had been given no evidence that Cramer had "even paid for their drinks." As such, the majority opinion held, the associations were insufficient to convict Cramer for treason, and the judgment of the Court of Appeals was reversed.
Writing in dissent, Justice William O. Douglas
William Orville Douglas (October 16, 1898January 19, 1980) was an American jurist who served as an associate justice of the Supreme Court of the United States, who was known for his strong progressive and civil libertarian views, and is often ci ...
claimed that acts, though innocent by nature, may serve a treasonous plan. Chief Justice Harlan Fiske Stone
Harlan is a given name and a surname which may refer to:
Surname
* Bob Harlan (born 1936 Robert E. Harlan), American football executive
*Bruce Harlan (1926–1959), American Olympic diver
*Byron B. Harlan (1886–1949), American politician
* Byron ...
concurred with the dissent.
Aftermath
Cramer later pleaded guilty to a lesser charge oftrading with the enemy
Trading with the enemy is a legal term of English origin that is used with a number of related meanings. It refers to:
#An offence at common law and under statute
#A ground for condemnation of ships in prize proceedings
#A ground for illegality a ...
and was sentenced to six years in prison.
See also
* '' Ex parte Bollman'': an earlier treason case before the Court.References
External links
* * 1945 in United States case law United States Constitution Article Three case law United States Supreme Court cases Treason Clause case law United States home front during World War II United States Supreme Court cases of the Stone Court {{SCOTUS-case-stub