The Pan-American Exposition came to an official end on Saturday, November 2. At the stroke of midnight, while ten buglers sounded taps from the Electric Tower, John Milburn threw a switch, and the sprawling fairgrounds—illuminated by 160,000 incandescent lights—went dark forever. To some observers, however, the ceremony seemed slightly redundant. The murder of the president two months earlier had already cast a deep shadow over the “Rainbow City” from which it had never fully emerged.1
By then, Leon Czolgosz was dead, electrocuted four days earlier at the state prison in Auburn, New York. Immediately after his execution, the top of his skull had been sawed off and his brain examined for signs of mental impairment. His corpse was then stuck inside a black-stained pine box, doused with sulfuric acid (to obliterate his identity), and buried in an unmarked grave in the prison cemetery.2
From the moment of the assassin’s capture to the day of his death and ignominious disposal, less than two months had elapsed—a striking contrast to the situation of Roland Molineux, who, at the time of Czolgosz’s execution, had been behind bars for more than two years, awaiting a final disposition of his case.
Still, Roland and his father no longer had cause for complaint. On Tuesday, October 15, the Court of Appeals had finally handed down its decision. In his battle against ex-senator Hill, John Milburn had triumphed. Had the great world’s fair he had helped shepherd into existence not climaxed in catastrophe, he, too, would have had every reason to celebrate.
The decision in the Molineux appeal—trumpeted on the front pages of newspapers across the country—would prove to be a judicial landmark, defining the conditions under which prosecutors could introduce evidence of previous crimes at a defendant’s trial. Generally speaking, wrote Justice William E. Werner in a formulation that even today is known as the “Molineux rule,” the state “cannot prove against a defendant any crime not alleged in the indictment.” This rule was intended as a constitutional safeguard, protecting a defendant from “the assumption that [he] was guilty of the crime charged because he had committed other, similar crimes in the past.”
To be sure, there were exceptions, instances where evidence of prior offenses might be admitted. For example, the prosecution could introduce “proof of another crime” if it helped to establish motive in “the specific crime charged.” In Roland’s case, however, neither this nor any other exception applied.
The motive for attempting to kill Cornish was, according to Werner, “hatred, engendered by quarrels between them.” The motive for poisoning Barnet, on the other hand, was “jealousy caused by the latter’s intervention in the love affair of the former.” Since the two motives had “no relation to each other,” evidence pertaining to the murder of Barnet threw “no light upon the motive which actuated the attempt upon the life of Cornish” and was therefore inadmissible.3
Based on this principle, the prevailing opinion held that Recorder Goff had erred in admitting testimony related to the death of Henry Barnet. The judgment of conviction against Roland Burnham Molineux was reversed and a new trial granted.4