Summary
The United States Supreme Court considered whether the arrest of a mail carrier under state criminal process constituted knowingly and wilfully obstructing or retarding the mail under federal law. The Court held that the statute did not apply to a temporary detention caused by the carrier’s arrest on an indictment for murder. The certified questions were answered in the negative.
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Practice areas
Questions Presented
- Whether the temporary detention of the mail caused by the arrest of its carrier pursuant to state bench warrants charging murder constituted an obstruction or retardation of the mail under the federal statute.
- Whether the arrest constituted knowingly and wilfully obstructing or retarding the passage of a mail carrier within the meaning of the statute.
- Whether a lawful arrest on criminal process may be treated as an obstruction under the statute when the resulting delay to the mail is incidental and unavoidable.
Holdings
- The statute does not apply to a temporary detention of the mail unavoidably caused by the lawful arrest of its carrier on an indictment for murder.
- The statute applies only to persons who know that their acts will obstruct or retard the mail or its carrier and perform those acts with the intention that they have that operation.
- A federal officer or employee is not immune from arrest on state criminal process charging felony, including murder, merely because temporary public inconvenience may result.
Key quotations
“The statute of Congress by its terms applies only to persons who 'knowing and wilfully' obstruct or retard the passage of the mail, or of its carrier; that is, to those who know that the acts performed will have that effect, and perform them with the intention that such shall be their operation.”
“All laws should receive a sensible construction. General terms should be so limited in their application as not to lead to injustice, oppression, or an absurd consequence.”
“The reason of the law in such cases should prevail over its letter.”
“The questions certified to us must be answered IN THE NEGATIVE.”
Factual background
Kirby, the sheriff of Gallatin County, Kentucky, received state bench warrants commanding him to arrest Farris, a mail carrier indicted for murder. Kirby and a lawfully summoned posse entered the steamboat General Buell, which was carrying the mail from Louisville to Cincinnati, and arrested Farris using only the force necessary to make the arrest. The arrest temporarily delayed the mail, but the defendants acted without an intent or purpose to obstruct or retard the mail or the carrier.
Procedural history
The defendants, including a county sheriff and members of his posse, arrested a mail carrier pursuant to Kentucky bench warrants issued on murder indictments. In the federal prosecution, they pleaded that the arrest was lawful and was not intended to obstruct the mail. After the United States demurred to the special plea, the lower court certified its divided questions to the Supreme Court, which answered both questions in the negative.