In the Matter of William F. Doyle, Appellant. Samuel H. Hofstader, Constituting a Legislative Committee…

Summary

The Court held that statutory immunity under Penal Law §381 shields a witness from contempt when refusing to answer questions about bribery of public officers, but Penal Law §584 does not extend such immunity to questions about conspiracies or attempts to bribe, so refusal to answer those is contumacious. The joint legislative resolution was not an act of amnesty and therefore cannot provide immunity. The order finding the appellant in contempt was affirmed, with a directive that he be committed until he answers the bribery question. Justice Pound dissented, arguing that the resolution does grant sufficient immunity and the contempt finding should be reversed.