Volume 287 — United States Reports

Powell v. Alabama, 287 U.S. 45 (1932), is a landmark United States Supreme Court decision in which the Court reversed the convictions of nine young black teenagers for allegedly raping two white women on a freight train near Scottsboro, Alabama. The majority of the Court reasoned that the right to retain and be represented by a lawyer was fundamental to a fair trial and that at least in some circumstances, the trial judge must inform a defendant of this right. In addition, if the defendant cannot afford a lawyer, the court must appoint one sufficiently far in advance of trial to permit the lawyer to prepare adequately for the trial.

Held: that “income,” as used in the revenue acts taxing income, adopted since the Sixteenth Amendment, has the same meaning that it had in the Act of 1909. Merchants Loan & Trust Co. v. Smietanka, 255 U. S. 509 , 519; see Southern Pacific Co. v. Lowe, 247 U. S. 330 , 335.

Held: some latitude of judgment as to the extent to which the component elements of worth are' to be separated, and a specific valuation allocated to each. The Commission has steadfastly adhered to these principles in the fulfilment of its task. Along the lines there charted, a thousand inventories and reports have been made, it is said, during the nineteen years that have gone by since the Valuation Act was passed.

Held: interpreting § 234 (a) (9), that the part of the depletion not allowed by the 1913 statute in the year in which it occurred could not be carried over and added to the depletable base used in computing the tax for a later year under the 1918 Act, which allowed depletion in full.

Held: on the basis of the record made before the Secretary, that there was evidence supporting his action.

Held: upon a complaint by the shipper, th'at the ratesi so approved were excessive and unreasonable. In this action to recover the excess so paid, the shipper recovered a judgment which was affirmed upon appeal. 91 Mont. 216 ; 7 P. (2d) 927 . The question, broadly stated, is whether the annulment by retroaction of rates valid when exacted is an unlawful taking of property within the Fourteenth Amendment.

Sorrells v. United States, 287 U.S. 435 (1932), is a Supreme Court case in which the justices unanimously recognized the entrapment defense. However, while the majority opinion by Chief Justice Charles Evans Hughes located the key to entrapment in the defendant's predisposition or lack thereof to commit the crime, Owen Roberts' concurring opinion proposed instead that it be rooted in an analysis of the conduct of the law enforcement agents making the arrest. Although the Court has stuck with predisposition, the dispute has hung over entrapment jurisprudence ever since.