People v. Molineux
Encyclopedia
People v. Molineux, 168 N.Y. 264
(1901), was a landmark decision by the Court of Appeals of New York.
ing. It was alleged that Molineux had a feud with the director of his local athletic club, Harry Cornish, and had mailed a bottle of Bromo-Seltzer
laced with cyanide
to Cornish. Katherine Adams was providing lodging to Cornish and came across the bottle. She drank the contents in an attempt to cure a headache and died within minutes, in the presence of Cornish who had been the intended target. The proceedings lasted from November 1899 to February 1900, making the People v. Molineux the longest and one of the most expensive trials in New York history to that date. The press offered wall-to-wall coverage, especially New York World
and New York Journal, then locked in the epic circulation struggle that began yellow journalism
.
Molineux was convicted but appealed to the Court of Appeals of New York, which eventually granted him a new trial. At the original trial, the prosecution had entered evidence to suggest that Molineux had been responsible for an earlier murder, that of a Henry C Barnett, with the aim of showing that he had a propensity to murder. However, Molineux had never been convicted for the murder of Barnett. The Appeals Court ruled that using 'evidence' of an unproven previous act of murder against the defendant in a subsequent unrelated trial violated the basic tenet of presumption of innocence
, and, therefore, such evidence was inadmissible (other than on five clearly defined grounds). Thus, "the state cannot prove against a defendant any crime not alleged in the indictment, either as a foundation for a separate punishment, or as aiding the proofs that he is guilty of the crime charged."
The decision was notable in its impact on the rules of admissibility of evidence
. Over one hundred years later, Judge Rosenblatt
of the New York Appeals Court
stated that the Molineux decision was a 'landmark case' which led to the precedent that:
in 1913. In his later years, he developed syphilitic dementia
, and he died in Kings Park State Hospital in 1917.
The prosecuting New York District Attorney Asa Bird Gardiner
was sacked by then New York Governor Theodore Roosevelt
on the grounds of incompetence.
Molineux's defense lawyer Bartow Weeks went on to become a New York Supreme Court
judge.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1901), was a landmark decision by the Court of Appeals of New York.
Trial
Roland Burnham Molineux was a chemist and social climber from Brooklyn. He was charged with first degree murder for having caused the death of Katherine J. Adams by poisonPoison
In the context of biology, poisons are substances that can cause disturbances to organisms, usually by chemical reaction or other activity on the molecular scale, when a sufficient quantity is absorbed by an organism....
ing. It was alleged that Molineux had a feud with the director of his local athletic club, Harry Cornish, and had mailed a bottle of Bromo-Seltzer
Bromo-Seltzer
Bromo-Seltzer , is an antacid used to relieve pain occurring together with heartburn, upset stomach, or acid indigestion. Originally produced by inventor Isaac E...
laced with cyanide
Cyanide
A cyanide is a chemical compound that contains the cyano group, -C≡N, which consists of a carbon atom triple-bonded to a nitrogen atom. Cyanides most commonly refer to salts of the anion CN−. Most cyanides are highly toxic....
to Cornish. Katherine Adams was providing lodging to Cornish and came across the bottle. She drank the contents in an attempt to cure a headache and died within minutes, in the presence of Cornish who had been the intended target. The proceedings lasted from November 1899 to February 1900, making the People v. Molineux the longest and one of the most expensive trials in New York history to that date. The press offered wall-to-wall coverage, especially New York World
New York World
The New York World was a newspaper published in New York City from 1860 until 1931. The paper played a major role in the history of American newspapers...
and New York Journal, then locked in the epic circulation struggle that began yellow journalism
Yellow journalism
Yellow journalism or the yellow press is a type of journalism that presents little or no legitimate well-researched news and instead uses eye-catching headlines to sell more newspapers. Techniques may include exaggerations of news events, scandal-mongering, or sensationalism...
.
Molineux was convicted but appealed to the Court of Appeals of New York, which eventually granted him a new trial. At the original trial, the prosecution had entered evidence to suggest that Molineux had been responsible for an earlier murder, that of a Henry C Barnett, with the aim of showing that he had a propensity to murder. However, Molineux had never been convicted for the murder of Barnett. The Appeals Court ruled that using 'evidence' of an unproven previous act of murder against the defendant in a subsequent unrelated trial violated the basic tenet of presumption of innocence
Presumption of innocence
The presumption of innocence, sometimes referred to by the Latin expression Ei incumbit probatio qui dicit, non qui negat, is the principle that one is considered innocent until proven guilty. Application of this principle is a legal right of the accused in a criminal trial, recognised in many...
, and, therefore, such evidence was inadmissible (other than on five clearly defined grounds). Thus, "the state cannot prove against a defendant any crime not alleged in the indictment, either as a foundation for a separate punishment, or as aiding the proofs that he is guilty of the crime charged."
The decision was notable in its impact on the rules of admissibility of evidence
Admissible evidence
Admissible evidence, in a court of law, is any testimonial, documentary, or tangible evidence that may be introduced to a factfinder—usually a judge or jury—in order to establish or to bolster a point put forth by a party to the proceeding...
. Over one hundred years later, Judge Rosenblatt
Albert Rosenblatt
Albert M. Rosenblatt is a retired judge from New York State.-Education:Rosenblatt attended the University of Pennsylvania, graduating in 1957, and Harvard Law School, where he received his law degree in 1960....
of the New York Appeals Court
New York Court of Appeals
The New York Court of Appeals is the highest court in the U.S. state of New York. The Court of Appeals consists of seven judges: the Chief Judge and six associate judges who are appointed by the Governor to 14-year terms...
stated that the Molineux decision was a 'landmark case' which led to the precedent that:
Aftermath
Molineux was acquitted at his subsequent retrial. A few months after his release, he was divorced by his wife on the grounds of mental cruelty. He wrote a play set in a prison, which was produced by David BelascoDavid Belasco
David Belasco was an American theatrical producer, impresario, director and playwright.-Biography:Born in San Francisco, California, where his Sephardic Jewish parents had moved from London, England, during the Gold Rush, he began working in a San Francisco theatre doing a variety of routine jobs,...
in 1913. In his later years, he developed syphilitic dementia
General paresis of the insane
General paresis, also known as general paralysis of the insane or paralytic dementia, is a neuropsychiatric disorder affecting the brain and central nervous system, caused by syphilis infection...
, and he died in Kings Park State Hospital in 1917.
The prosecuting New York District Attorney Asa Bird Gardiner
Asa Bird Gardiner
Asa Bird Gardiner was a controversial American soldier, attorney, and prosecutor. He received the Medal of Honor for his service in the American Civil War in 1872, it was rescinded when the supporting documentation was not found...
was sacked by then New York Governor Theodore Roosevelt
Theodore Roosevelt
Theodore "Teddy" Roosevelt was the 26th President of the United States . He is noted for his exuberant personality, range of interests and achievements, and his leadership of the Progressive Movement, as well as his "cowboy" persona and robust masculinity...
on the grounds of incompetence.
Molineux's defense lawyer Bartow Weeks went on to become a New York Supreme Court
New York Supreme Court
The Supreme Court of the State of New York is the trial-level court of general jurisdiction in thestate court system of New York, United States. There is a supreme court in each of New York State's 62 counties, although some smaller counties share judges with neighboring counties...
judge.