United States v. Apfelbaum
United States Supreme Court
445 U.S. 115 (1980)
- Written by Sharon Feldman, JD
Facts
Stanley Apfelbaum (defendant) was called to testify before a grand jury investigating certain criminal activities. Apfelbaum asserted his Fifth Amendment privilege against compulsory self-incrimination. The district court entered an order, pursuant to the federal immunity statute, granting Apfelbaum immunity and compelling him to testify. Apfelbaum made false statements during his grand jury testimony and was charged with making false declarations before the grand jury. During Apfelbaum’s trial, the government introduced portions of Apfelbaum’s immunized testimony to put the alleged false statements in context and prove that Apfelbaum knew the statements were false. Apfelbaum was convicted. The Third Circuit reversed, holding that the excerpts of Apfelbaum’s testimony that did not constitute the corpus delicti or core of the false-declaration charge were not admissible. The Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, J.)
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