State v. Linkhaw

State v. Linkhaw, 69 N.C. 214 (N.C. 1873), was a case in which the North Carolina Supreme Court reversed a criminal conviction for disturbing a religious congregation. Defendant William Linkhaw, a Methodist, sang so poorly in church that a grand jury indicted him for disrupting the church's services. At trial, the evidence showed that Linkhaw's singing was so bad that the pastor once declined to sing a hymn at all. When a witness imitated Linkhaw's manner, the entire courtroom burst into laughter. Some of his fellow congregants found Linkhaw's singing amusing, but others were decidedly displeased. They asked him to cease singing, but Linkhaw, a faithfully religious man, replied that he felt a duty to worship God. All parties agreed that Linkhaw did not mean to disturb the service, but trial judge Daniel L. Russell ruled that he could nonetheless be held responsible because he ought to have known that his acts would result in a disruption of the congregation. The jury found Linkhaw guilty, and Russell fined him one penny. Linkhaw appealed to the North Carolina Supreme Court, which unanimously vacated the conviction. In an opinion by Justice Thomas Settle, the court ruled that Linkhaw could not be found guilty when he was genuinely trying to worship. Settle suggested that the matter was more appropriate for church discipline than for the courts of law. Because of its peculiar nature, the case attracted significant public attention from across the world.