Haynes v. United States
Encyclopedia
Haynes v. United States, , was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 decision interpreting the Fifth Amendment to the United States Constitution
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...

's self-incrimination clause. Haynes extended the Fifth Amendment protections elucidated in Marchetti v. United States, 390 U.S. 39, 57 (1968).

Background of the case

The National Firearms Act of 1934 required the registration of certain types of firearms. Miles Edward Haynes was a convicted
Conviction
In law, a conviction is the verdict that results when a court of law finds a defendant guilty of a crime.The opposite of a conviction is an acquittal . In Scotland and in the Netherlands, there can also be a verdict of "not proven", which counts as an acquittal...

 felon
Felon
Felon may refer to:* Someone who commits a felony* Whitlow, a purulent inflammation of the pulp of a finger* A slang term for Summer Mastitis in cows in the United Kingdom* Felon, Territoire de Belfort, a commune of the Franche-Comté region, in France...

 who was charged with failing to register a firearm under the Act. Haynes argued that, because he was a convicted felon and thus prohibited from owning a firearm, requiring him to register was essentially requiring him to make an open admission to the government that he was in violation of the law, which was thus a violation of his right not to incriminate himself.

Majority opinion

In 7-1 decision, the Court ruled in favor of Haynes. Earl Warren
Earl Warren
Earl Warren was the 14th Chief Justice of the United States.He is known for the sweeping decisions of the Warren Court, which ended school segregation and transformed many areas of American law, especially regarding the rights of the accused, ending public-school-sponsored prayer, and requiring...

 dissented in a one sentence opinion and Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...

 did not participate in the ruling.

As with many other 5th amendment cases, felons and others prohibited from possessing firearms could not be compelled to incriminate themselves through registration. The National Firearm Act was amended after Haynes and the new registration provision was upheld in United States v. Freed
United States v. Freed
United States v. Freed, , was a case in which the U.S. Supreme Court ruled that the buyer of unregistered hand grenades was subject to criminal liability, despite a lack of mens rea on his part. Thus, the court upheld the conviction of a defendant for a crime committed by someone else...

, 401 U.S. 601 (1971).

Since the decision offers felons (and, by extrapolation, all other prohibited possessors) a considerable degree of immunity from gun registration, it is often cited in the American gun rights
Gun politics in the United States
Gun politics in the United States refers to an ongoing political and social debate regarding both the restriction and availability of firearms within the United States. It has long been among the most controversial and intractable issues in American politics...

debate.

Further reading

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