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United States v. Callahan

United States District Court for the District of Minnesota

442 F. Supp. 1213 (1978)

Facts

Callahan (defendant) was indicted by a grand jury under a federal kidnapping statute. During the grand jury proceedings, the prosecutor used evidence that Callahan underwent and failed a polygraph examination regarding his involvement with the alleged crime. Before trial, Callahan moved to dismiss the indictment based on the prosecution’s (plaintiff) use of the polygraph as evidence. The court withheld rendering a decision. A petit jury subsequently found Callahan guilty of violating the statute beyond a reasonable doubt. Callahan moved for judgment of acquittal or a new trial, arguing that the prosecution referencing the polygraph was impermissible and, even if permissible, the prosecutor had a duty to inform the grand jury that the examination constituted hearsay.

Rule of Law

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Issue

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Holding and Reasoning (Devitt, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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