Krulewitch v. United States
United States Supreme Court
336 U.S. 440 (1949)
- Written by Craig Conway, LLM
Facts
Krulewitch (defendant) and another person were charged with conspiring to violate and violating the Mann Act, a statute that prohibited interstate transportation for the purposes of prostitution. At trial, the government sought to admit an alleged coconspirator’s statement that implicated Krulewitch in the charged crimes. Although the conspiracy’s main objective—i.e., transportation for prostitution—had been completed by the time of the coconspirator’s statement, the government argued that the conspiracy had continued with a new objective—concealment of the crime—even after the transportation was completed. The continued existence of the conspiracy was important because a certain doctrine allowed any statements made by any conspirator during the conspiracy to be admissible at trial against all other coconspirators, even though such statements would ordinarily be excluded as hearsay. The trial court admitted the coconspirator’s statement, and Krulewitch was convicted. The appellate court affirmed, agreeing with the government’s position that the coconspirator’s statement had been made in furtherance of the continuing conspiracy to conceal the alleged crime. The United States Supreme Court granted certiorari to review.
Rule of Law
Issue
Holding and Reasoning (Black, J.)
Concurrence (Jackson, J.)
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