Locke v. United States (1813) – Case Brief Summary (U.S. Supreme Court)

In Locke v. United States (1813) 11 U.S. 339, a cargo belonging to the plaintiff in error had been condemned under a libel containing 11 counts.

Chief Justice John Marshall speaking for the Supreme Court, found it unnecessary to consider Locke's challenges to all 11 counts. He declared, simply enough, "The Court however, is of opinion, that the 4th count is good, and this renders it unnecessary to decide on the other." (Id., at 344.)

Under the doctrine first enunciated by Chief Justice Marshall in Locke v. United States, and consistently followed thereafter, if the evidence on any one count of a multi-count indictment is sufficient to sustain the verdict, it is not necessary to examine the other counts where the sentences imposed thereon are made to run concurrently

That doctrine, which found its genesis in Locke v. United States has been applied by the federal courts in situations where a defendant has been validly convicted on any one count of a multi-count indictment for which concurrent sentences are imposed to declare that it is unnecessary to consider the others.

In Locke v. United States, Chief Justice Marshall said, "the term `probable cause', according to its usual acceptation, means less than evidence which would justify condemnation; and in all cases of seizure, has a fixed and well-known meaning, it imports a seizure made under circumstances which warrant suspicion.Chief Justice Marshall also said that "The substance of all the definitions" of probable cause "is a reasonable ground for belief of guilt." And this "means less than evidence which would justify condemnation" or conviction.