Also known as: ignoramuses · no bill · we do not know
Written by attorneys — see sources below.
A notation formerly endorsed by a grand jury on a bill of indictment to signify rejection of the proposed charges. The endorsement indicated that the grand jury found insufficient grounds to proceed. The accused was then discharged without further answer or trial.
Imani Idowu faces a proposed indictment after a legislative dispute. The grand jury reviews the evidence in secret session. Upon finding the accusations groundless, the jurors endorse the bill ignoramus. Imani is released immediately without any further proceedings.
Iris Irons sues the city after street repairs damage her property. Prosecutors present a proposed indictment alleging a constitutional violation by state actors. The grand jury determines the evidence fails to support the charge. It returns the bill marked ignoramus, freeing the city officials from prosecution.
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View caseIsmael Ibrahim is arrested after officers find contraband during a street encounter. Prosecutors seek an indictment based on the seized evidence. The grand jury concludes the stop lacked adequate justification. It endorses the bill ignoramus and discharges Ismael without trial.
In March 1965, New York City police officer Anthony Martin observed appellant Sibron over an eight-hour period in the vicinity of 742 Broadway in Brooklyn. During this time, Martin saw Sibron speaking with six to eight known narcotics addicts but did not overhear the conversations or see any objects pass between them. Later in the evening, after Sibron entered a restaurant and spoke with three more addicts, Martin approached him, directed him outside, and reached into Sibron's pocket to seize several glassine envelopes containing heroin. On July 10, 1964, Mount Vernon police officer Samuel Lasky, while at home in his apartment building where he had lived for twelve years, heard noises at his door and observed two men he did not recognize tiptoeing in the hallway. After the men fled down the stairs upon Lasky emerging from his apartment armed, Lasky pursued and apprehended appellant Peters between the fourth and fifth floors. Lasky then frisked Peters and removed a plastic envelope containing burglar's tools from his pocket. Both Sibron and Peters were charged with crimes based on the seized evidence. They moved to suppress the items prior to trial on Fourth Amendment grounds. After the trial courts denied the motions, both pleaded guilty while preserving their right to appeal the suppression rulings. The Appellate Division and the New York Court of Appeals affirmed the convictions, upholding the searches under New York's stop-and-frisk statute. The Supreme Court granted certiorari in both cases to address the constitutional questions presented by the application of the statute. Sibron received a six-month sentence and was released after serving his term before his appeal could be fully processed through the state courts. He was arrested on March 9, 1965, remained in jail due to indigency until his sentence expired on July 10, 1965, and could not obtain bail pending appeal under state law. Delays in the New York court system meant his case reached the Court of Appeals only after release.
View caseIndia Inoue is charged with a drug offense carrying an enhanced penalty based on judicial fact-finding. Prosecutors submit a bill seeking the higher sentence range. The grand jury finds the supporting facts insufficient. It marks the bill ignoramus, limiting any potential conviction to the base offense.
In 1998, Ralph Howard Blakely abducted his estranged wife Yolanda from their orchard home in Grant County, Washington. He bound her with duct tape and forced her at knifepoint into a wooden box in the bed of his pickup truck while imploring her to dismiss divorce and trust proceedings. When their 13-year-old son Ralphy returned from school, Blakely ordered him to follow in another car under threat of harming Yolanda with a shotgun. Ralphy escaped at a gas station and sought help, but Blakely continued with Yolanda to a friend's house in Montana before his arrest. The State initially charged Blakely with first-degree kidnapping but reached a plea agreement that reduced the charge to second-degree kidnapping involving domestic violence and use of a firearm. Blakely entered a guilty plea admitting the elements of the reduced charge along with the domestic-violence and firearm allegations, but no other relevant facts. Washington law classified the offense as a class B felony carrying a statutory maximum of ten years, yet specified a standard sentencing range of 49 to 53 months for this offender score and offense level. At sentencing the State recommended a term within the standard range. After hearing Yolanda's account of the incident, the judge rejected the recommendation and conducted a three-day bench hearing that included testimony from Blakely, Yolanda, Ralphy, a police officer, and medical experts. The judge issued 32 findings of fact detailing the defendant's motivation, methods, and violation of a restraining order, then concluded that Blakely had acted with deliberate cruelty, a statutorily enumerated aggravating factor. The judge imposed an exceptional sentence of 90 months, 37 months above the standard maximum. Blakely appealed, contending that the sentencing procedure deprived him of the right to jury determination of facts essential to his sentence. The Washington Court of Appeals affirmed, relying on the state supreme court's earlier rejection of a similar challenge, and the Washington Supreme Court denied discretionary review. The United States Supreme Court granted certiorari to examine the sentencing procedure under the Sixth Amendment.
View caseIvy Ibarra delivers a heated address at a public rally that draws complaints. Prosecutors present a bill alleging breach of the peace. The grand jury determines the speech falls within protected expression. It endorses the bill ignoramus and frees Ivy without further action.
On February 7, 1946, Albert Terminiello delivered a speech in the auditorium of the West End Women's Club in Chicago to an audience of about eight hundred people under the auspices of the Christian Veterans of America. An overflow crowd of about one thousand persons gathered outside the auditorium to protest the meeting. The crowd was angry and turbulent, with many making threats against the speaker, shouting, and attempting to force their way into the building while the police proved unable to maintain order. Terminiello was arrested and charged under a Chicago ordinance making it unlawful to make any improper noise, riot, disturbance, breach of the peace, or diversion tending to a breach of the peace. At trial the court instructed the jury that misbehavior may constitute a breach of the peace if it stirs the public to anger, invites dispute, brings about a condition of unrest, or creates a disturbance, and the jury returned a verdict of guilty resulting in a fine of one hundred dollars. The Illinois Appellate Court and the Illinois Supreme Court both affirmed the conviction. The Supreme Court of the United States granted certiorari to review the case.
View caseIain Irons suffers a seizure while driving and causes an accident. Prosecutors seek an indictment for reckless driving based on the incident. The grand jury concludes the conduct was not voluntary. It returns the bill marked ignoramus, ending the prosecution.
On March 14, 1955, at about 3:30 p.m., defendant Emil A. Decina was driving his car alone in a northerly direction on Delaware Avenue in Buffalo when the vehicle swerved left across the center line and then sharply right, mounting the easterly curb at high speed. The car struck six schoolgirls walking on the sidewalk. Three children aged 6 to 12 were killed on the scene and a fourth child died two days later in the hospital from injuries sustained in the accident. After the collision, the car continued, struck a lamppost, and crashed through a brick wall into a grocery store, where Decina was found stooped over the wheel appearing dazed. Decina was taken to E. J. Meyer Memorial Hospital at 5:30 p.m. A pink slip from the Buffalo Police Department accompanied him, requesting examination and noting the fatal accident and the recommendation of the District Attorney. There, Dr. Wechter, a resident physician, spoke with Decina in the presence of a police guard and obtained his medical history of epilepsy, including prior treatment, operations, seizures, and medication. Decina was indicted for violating section 1053-a of the Penal Law. Following conviction after his demurrer was overruled, the Appellate Division reversed on the law and granted a new trial on the ground that the transactions with Dr. Wechter were privileged, while sustaining the overruling of the demurrer. Both the People and the defendant appealed.
View caseAn ignoramus endorsement means the grand jury found the evidence insufficient to support the proposed charges. The accused is discharged without being held for trial. No further answer or proceeding follows from that bill.
A true bill indicates the grand jury found probable cause to support the charges and returns an indictment. Ignoramus signals rejection of the bill. The two outcomes determine whether prosecution proceeds or ends at the grand jury stage.
Modern grand juries typically return a no bill or not a true bill rather than the Latin term. The underlying function remains identical. The endorsement still discharges the accused when the grand jury finds the evidence inadequate.
A majority of grand jurors must decline to indict. In the federal system twelve affirmative votes are needed for a true bill out of at least sixteen members. Failure to reach that threshold produces an ignoramus or no bill result.