## Facts

- Reagan was tried in the United States Circuit Court for the Western District of Texas for unlawfully and fraudulently receiving and concealing 40 head of cattle smuggled from Mexico, with intent to defraud the United States, in violation of Revised Statutes § 3082.
- A jury found Reagan guilty on April 30, 1894, and the court entered judgment on the verdict.
- Reagan testified in his own defense.
- The trial judge instructed the jury that, in evaluating Reagan’s credibility, it could consider his personal interest in the outcome of the case.
- Reagan challenged, among other matters, (i) the number of peremptory challenges allowed to him and (ii) the credibility instruction focusing on his interest as the accused.

## Issues

1. Whether an offense under Revised Statutes § 3082, punishable by a fine up to $5,000 or imprisonment up to two years, or both, qualifies as a “felony” under Revised Statutes § 819 so as to entitle the defendant to ten peremptory challenges rather than three.
2. Whether it is error for a trial court to instruct jurors, when the defendant testifies, that they may consider the defendant’s personal interest in the result when assessing the credibility and weight of his testimony.

## Decision

- The Supreme Court affirmed the judgment of conviction.
- The Court held the § 3082 offense was not a “felony” within the meaning of § 819; therefore, limiting the defense to three peremptory challenges was proper.
- The Court held it was not error for the trial judge to remind the jury that the defendant’s interest in the trial’s outcome may affect the weight of his testimony, so long as the instruction is part of the ordinary credibility framework and does not direct jurors to reject the testimony.

## Legal Principles

- For peremptory challenges under Revised Statutes § 819, whether an offense is a “felony” turns on Congress’s intended meaning in that provision, not solely on the possibility of penitentiary-eligible imprisonment or state-law labeling.
- In assessing witness credibility, jurors may consider a witness’s interest in the litigation’s outcome; a court may specifically point out that a defendant who testifies has a unique personal stake in the result.
- An instruction identifying the defendant as an interested witness is permissible when it does not create a presumption of falsity, does not instruct jurors to disbelieve the defendant, and is framed as one factor among the usual credibility considerations.

## Conclusion

The Supreme Court affirmed Reagan’s conviction, ruling that the charged smuggling-related offense was not a “felony” for purposes of the federal peremptory-challenge statute and that a trial judge may instruct jurors to consider a testifying defendant’s interest in the case when weighing credibility.


Reagan v. United States, 157 U.S. 301 (1895)