The Williams case was a prosecution for murder on the high seas. The defendants, accused of killing the captain of their ship and other men, were examined under oath before a United States consul in Havana, Cuba. They denied the allegations. When they were implicated by a witness, however, the defendants changed their story, confessing to the murder and describing the crime. The defendants were not under oath when they made the latter statements. All their statements—the sworn denials and the unsworn confessions—were admitted into evidence at trial, and the defendants were convicted before U.S. District Judge Asher Ware.

The defendants sought a new trial on the grounds that they would not have confessed had they been aware they were not under oath. They also relied upon the corpus delicti (“body of the crime”) rule in arguing that their confessions should have been excluded. The rule held that the prosecution must prove independently that a crime had been committed in order to introduce a defendant’s confession to that crime. Here, the bodies of the alleged victims had not been recovered, and the defendants argued that the prosecution had failed to produce other proof that the murders had occurred.

In ruling on the defendants’ motion, Justice Clifford noted that the issue of whether the defendants had confessed involuntarily had been left to the jury, with the instruction to disregard the confessions if they believed the defendants were unaware they were not under oath. Clifford found it unnecessary to rule on whether a confession not made under oath was admissible, as he believed the jury instruction given at trial “was in favor of the prisoners.”

As to the question of corpus delicti, Clifford acknowledged that the general rule in cases of felonious homicide was that discovery of the body of the alleged victim was required “whenever direct proof exists and it is practicable to obtain it.” Nevertheless, it would be unwise for such a rule to be enforced rigidly in all cases, Clifford pointed out. “A murder[er] would only have to consume the body by fire, or decompose it by chemical means, or sink it in the depth of the sea, and the laws of society would be powerless to punish the offender.” On the high seas in particular, bodies were rarely recovered. A rule disallowing other proof of the crime would amount to blanket immunity for such murders.

Clifford went on to explain that “[m]any facts and circumstances were proved at the trial, independently of the confessions, tending to show that the crime had been committed; and some of the circumstances thus proved were of a character strongly to implicate the prisoners in the transaction.” Among these were that the prisoners had been picked up in a different boat in the open sea but had in their possession the compass and register from their original ship as well as the captain’s watch and clothing of the murdered men. In sum, Clifford held that the corpus delicti need not be fully proved independent of a confession. “All that can be required is, that there should be corroborative evidence tending to prove the facts embraced in the confession.” The motion for a new trial was denied.