General Electric Co. v. International Union, United Automobile, Aircraft & Agricultural Implement Workers

118 N.E.2d 708, 68 Ohio Law. Abs. 54, 52 Ohio Op. 458, 1953 Ohio Misc. LEXIS 359
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedJune 22, 1953
DocketNo. A-137254
StatusPublished

This text of 118 N.E.2d 708 (General Electric Co. v. International Union, United Automobile, Aircraft & Agricultural Implement Workers) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
General Electric Co. v. International Union, United Automobile, Aircraft & Agricultural Implement Workers, 118 N.E.2d 708, 68 Ohio Law. Abs. 54, 52 Ohio Op. 458, 1953 Ohio Misc. LEXIS 359 (Ohio Super. Ct. 1953).

Opinion

[56]*56OPINION

By WEBER, J.

The amended charge of contempt contains three different charges. This hearing has been conducted on the first charge which alleges that Ralph W. Gabe as the agent and member of the union committed certain acts on May 11, 1953 in violation of the injunction issued in case number A-137254 on April 13, 1953.

The plaintiff called the defendant as a witness to testify as upon cross-examination. Before the oath was administered, counsel for the defendant objected, without stating the grounds for the objection, to the defendant testifying. The court overruled the objection upon the assumption that the hearing was a civil proceeding. The oath was then administered and the defendant was asked whether he was a member of the union, to which he answered in the affirmative. No further objection was made. After the plaintiff rested its case, counsel for the defendant moved as follows:

“If the court please we move to dismiss the charge against the defendant Gabe and to declare a mistrial, particularly on the ground that his constitutional rights have been violated in having been called as a witness over his objection, and asked to give testimony and having been compelled to give testimony.”

.The first question presented is whether this is a criminal proceeding. Contempt proceedings are said to be quasi criminal, that is, they may be considered under certain circumstances as civil and under certain ciroumstances as criminal. The primary test is whether the principal purpose is to confer a benefit or restitution upon the plaintiff, or to punish the accused. If the injunctive order has commanded the accused to perform an act and the accused has failed to perform, the contempt proceeding is for the benefit of the plaintiff and the hearing is a civil proceeding. If the injunctive order has prohibited the doing of an act and that act has been completely performed in violation of the order, the hearing is usually held to be a criminal proceeding. However, it is not always so held. If the injunction was issued in a suit brought by a private party in which restitution by way of damages was sought and the contempt charge is filed in the same case, it may be held that the primary purpose set forth in the petition is restitution and for that reason that the hearing is a civil [57]*57proceeding, although the accused has completely performed an act prohibited by the injunction. Remington Rand, Inc. v. International Association of Machinists, 6 O. O. 308; Hayes v. Hayes, 11 O. O. 10; Gompers v. Buck Stove Company, 221 U. S. 418.

The next question is raised by the contention of the plaintiff that the objection to the defendant testifying against himself is a personal privilege and one which must be asserted by the defendant himself and which cannot be asserted by the defendant's attorney or anyone else and also that it must be asserted after the oath has been administered to the defendant. These rules have been applied in a number of Ohio cases. State of Ohio v. Cox, 87 Oh St 313; Burke v. State of Ohio, 104 Oh St 220; Lawson v. Hudephol, 46 O. O. 11.

In order to determine whether these rules should be applied to the situation here presented, an examination should be made of the nature of the situation in which they were applied and the reason for applying them.

When a witness is subpoenaed to testify before a grand jury concerning matters in which it may be developed he was engaged, it is net absolutely certain before he is sworn and questioned that he will be1 testifying against himself. He is not then the defendant accused of the offense which is the subject of the inquiry by the grand jury and it is not self-evident that if examined he will testify against himself. Knowledge that answers to particular questions will tend to incriminate such a witness exists only in the inner recesses of the mind of the witness. His attorney, even if permitted to be present, could not base an objection upon absolute firsthand knowledge. Questions calling for incriminating answers cannot be asked until the oath has been administered.

The same is true, but to a greater extent, where, in a criminal trial, one who is not the defendant therein is called as a witness.

In this case the defendant himself was called as a witness. To be admissible in a criminal trial the evidence must be relevant to the criminal act charged against the defendant. The only competent evidence is that which tends to prove the innocence or the guilt of the defendant. Where the defendant is called as upon cross-examination in a criminal trial the subject matter of possible self incrimination is not something existing only in the inner recesses of the defendant’s mind. It has been disclosed in the charge against him. It is as well known to the party calling the defendant and to the defendant’s attorney as it is to the defendant. In calling the defendant as upon cross-examination the intended purpose is to [58]*58solicit from him testimony which tends to prove his guilt. To reveal this purpose it is not necessary that questions be asked and answers be given under oath. Such purpose is self-evident. In such a situation there is no sound reason why the defendant’s attorney, who has general authority to take all steps necessary to protect him, cannot make a valid objection to calling the defendant as a witness, even before the oath has been administered. Overruling such an objection is a direction by the court to the defendant to testify and is compulsion. Since the hearing must be treated as a criminal proceeding, the court committed error in overruling the objection.

The motion of the defendant is twofold; to declare a mistrial and to dismiss the defendant from the first charge set forth in the amended charge of contempt. Both phases of the motion are based upon the claim, which the court sustains, that to make the defendant amenable to the restraining order, he must have had actual knowledge of the restraining order or constructive knowledge by reason of his being an agent or member of the union; also the claim, which the court sustains, that the only evidence of such knowledge on the part of the defendant is his testimony that he was a member of the union at the time the acts complained of were committed and that such testimony is incompetent because it violates his constitutional right not to be compelled to testify against himself. However, the two parts of the defendant’s motion are inconsistent. A ruling that there is technically a mistrial must be upon the premise that a finding that the defendant is guilty necessarily would be based, at least in part, upon such incompetent testimony and would require a retrial. In order to grant the motion for a dismissal, the court must construe the motion for a mistrial as a motion to strike said incompetent testimony from the record, which, if granted, deprives the plaintiff, at the time it rested, of all proof of one of the essential elements of its case, that is that the defendant was amenable to the restraining order.

The following cases approve the rule that such incompetent evidence, whether the proceeding is civil or criminal, and particularly if the case is tried to the court, should be stricken from the case or disregarded instead of declaring a mistrial and granting a retrial.

Booker v. Cincinnati (1936 C. P.), 22 Abs 286, in which the accused was charged with drunken driving.

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Related

Seaman Field v. United States
34 U.S. 182 (Supreme Court, 1834)
Gompers v. Bucks Stove & Range Co.
221 U.S. 418 (Supreme Court, 1911)
Carolene Products Co. v. United States
323 U.S. 18 (Supreme Court, 1944)
Driggs v. State
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Booker v. Cincinnati city
22 Ohio Law. Abs. 286 (Ohio Court of Appeals, 1936)
Oates v. United States
233 F. 201 (Fourth Circuit, 1916)

Cite This Page — Counsel Stack

Bluebook (online)
118 N.E.2d 708, 68 Ohio Law. Abs. 54, 52 Ohio Op. 458, 1953 Ohio Misc. LEXIS 359, Counsel Stack Legal Research, https://law.counselstack.com/opinion/general-electric-co-v-international-union-united-automobile-aircraft-ohctcomplhamilt-1953.