Defendant wrote two letters to the grand jury, then in session, asking leave to appear before it to present evidence of a conspiracy, described therein in highly inflammatory language, between a newspaper, the county assessor and the state's attorney to defraud the state of many millions of revenue by the illegal omission of the newspaper's personal property from the county tax rolls. The state's attorney filed an information incorporating these letters. The trial court found that defendant was guilty of criminal contempt. On appeal, defendant contended that this conviction deprived him of his constitutional right of free speech. Held, the letters constitute contempt of court as an unauthorized interference with the administration of justice, even though the letters do not refer to cases pending before the grand jury. People v. Parker, 374 Ill. 524, 30 N. E. (2d) 11 (1940),1 cert. den. 313 U.S. 560, 61 S. Ct. 836 (1941).
James K. Lindsay,
CRIMINAL LAW AND PROCEDURE - VOLUNTARY COMMUNICATION TO GRAND JURY AS CONTEMPT,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol40/iss2/13