CONSTITUTIONAL LAW-PROCEDURAL DUE PROCESS DENIED BY MICHIGAN\u27S ONE-MAN GRAND JURY\u27\u27

Petitioner was summoned to appear as a witness before one of Oakland County\u27s judges who was then acting in the capacity of one-man grand juror. This proceeding was attended only by petitioner, the judge grand juror, and two other circuit judges acting as advisers to the latter. The purpose was to investigate alleged misconduct on the part of law-enforcing officials through the acceptance of bribes in the form of sales of worthless bonds on pin-ball machines. Petitioner admitted purchasing these bonds but could. not recall just what he had done with them when they had expired. Concluding that the petitioner\u27s answers were evasive and that his story did not jell the judge immediately charged petitioner with contempt, convicted him, and sentenced him to jail-all without leaving the room. With only a part of the testimony on record the Supreme Court of Michigan denied the petitioner\u27s motion for habeas corpus by an evenly divided court. On certiorari, held, reversed, two justices dissenting. Such a conviction is unconstitutional as a denial of due process. In re William Oliver, (U.S. 1948) 68 S.Ct. 499