UNITED STATES v. MILLER

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Case Basics
Docket No. 
83-1750
Petitioner 
United States
Respondent 
James Rual Miller
Advocates
(Deputy Solicitor General, Department of Justice, argued the cause for the United States)
(appointed by the Court, argued the cause for the respondent)
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Facts of the Case 

An indictment issued by a grand jury charged James Miller with fraud. The indictment alleged he conspired with a burglar and overstated the value of the stolen items so his insurer would pay him more in damages recovery. The prosecution presented evidence proving that Miller had overstated the value of the items but did not try to establish that he had conspired with the burglar. The jury found his overstatement of value sufficient to convict him of fraud. Miller argued that by convicting him despite the fact that the prosecutors only addressed part of the indictment, the jury violated his Fifth Amendment right to be tried only on a grand jury indictment. The United States Court of Appeals for the Ninth Circuit agreed and reversed his conviction.

Question 

Does the Fifth Amendment right to be tried on a grand jury indictment provide that the jury can only convict the accused if the prosecution addresses every allegation included in the indictment?

Conclusion 
Decision: 8 votes for United States, 0 vote(s) against
Legal provision: Grand Jury

No. Justice Thurgood Marshall delivered the decision for an 8-0 court. The Court maintained that an indictment is valid so long as it "clearly set[s] out the offense for which [the accused] was ultimately convicted." In this case, the defense clearly understood that Miller could be convicted for fraud solely because he overstated the value of the stolen items. Failing to convict him on other grounds did not annul his proven criminal conduct. The allegation of conspiring with a burglar constituted another "means of committing the same crime" and could be "treated as a useless averment that may be ignored" once the prosecution dropped it.

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UNITED STATES v. MILLER. The Oyez Project at IIT Chicago-Kent College of Law. 21 June 2014. <http://www.oyez.org/cases/1980-1989/1984/1984_83_1750>.
UNITED STATES v. MILLER, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1984/1984_83_1750 (last visited June 21, 2014).
"UNITED STATES v. MILLER," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 21, 2014, http://www.oyez.org/cases/1980-1989/1984/1984_83_1750.