Home > Journals > Michigan Law Review > MLR > Volume 54 > Issue 3 (1956)
Article Title
Constitutional Law - Due Process - Power of Michigan One-Man Grand Jury to Punish Contempt
Abstract
Petitioners were two witnesses called before a Detroit Recorder's Court judge sitting as a Michigan one-man grand jury to investigate suspected police corruption. During the hearings both petitioners were cited for contempt. An order to show cause why they should not be punished was issued by the judge. Subsequently, in open hearings, the same judge convicted and sentenced petitioners. The Michigan Supreme Court affirmed. On certiorari to the United States Supreme Court, held, reversed. To allow a judge who sat as a one-man grand jury to preside at a contempt hearing regarding the same witnesses violates due process. In re Murchison, (U.S. 1955) 75 S.Ct. 623.