Barrett v. United States (1898)

Barrett v. United States, 169 U.S. 218 (1898), was a case in which the Supreme Court of the United States held that South Carolina had never effectively been subdivided into separate judicial districts. Therefore, it was held, a criminal defendant allegedly tried in one district for a crime committed in the other had in fact been permissibly been tried in a separate division of a single district.

Facts of the case

The defendant, Charles P. Barrett, was one of a group of men in Spartanburg, South Carolina, alleged to have been involved in a conspiracy to defraud companies selling items by mail order. Barrett, apparently an attorney, arranged to have post offices established in rural areas with the name of each post office being the name of another defendant (e.g. Owens, McElrath, Wyatt). Companies sending mail to those individuals would thereby be led to think that the individuals were proprietors of the respective post offices. Barrett also created a letterhead on which to send orders for goods, in order to further induce the trust of the companies from which orders were placed, and his co-conspirators ordered goods including encyclopedias, a piano, an organ, a desk, and a safe, none of which were ever paid for. The fraud was far reaching, as the trial court reported that parties coming to testify that they had been defrauded:

...came from New York and Chicago, from New Jersey and Pennsylvania, from Boston, Baltimore, and Atlanta, from Washington, Richmond, and Savannah, from Charlotte and Augusta...

Barrett and his co-conspirators were charged with conspiracy to defraud, and the trial was held in the United States circuit court in Columbia, South Carolina, before judge William H. Brawley.