Murphy v. Waterfront Commission of New York Harbor
Citation and Court
378 U.S. 52 (1964) — Supreme Court of the United States
Facts
Murphy and others were subpoenaed to testify before the Waterfront Commission, a bi-state agency. They were granted immunity under New Jersey and New York law but refused to answer questions, fearing their testimony could be used against them in a federal prosecution. No federal immunity had been granted.
Issue
Does the Fifth Amendment privilege against self-incrimination protect a state witness from having his compelled testimony (given under a grant of state immunity) used against him in a federal prosecution?
Holding
Yes; the Fifth Amendment prohibits the federal government from using testimony compelled under a grant of state immunity in a federal prosecution.
Rule / Doctrine
When a state grants a witness immunity and compels his testimony, the federal government may not use that testimony—or its fruits—against the witness in a federal prosecution. The Fifth Amendment privilege is federalized through this doctrine of use and derivative-use immunity across governmental units.
Significance
Murphy establishes the transactional scope of immunity across state-federal lines and is the foundation for the distinction between transactional immunity (broader) and use-and-derivative-use immunity (narrower, sufficient to override the privilege). It is foundational for understanding the Fifth Amendment’s scope in multi-jurisdictional investigations, though it appears in the Criminal Investigations curriculum largely to set the stage for subsequent immunity doctrine.