procedure provision of the Bill of Rights not to be incorporated. Other Sufficiency of an indictment In United States v. Simmons (1877), the Court assessed the sufficiency of an indictment charging the production of untaxed alcohol. The Court held that an indictment must either name the defendant or state that the defendant's name is unknown. In United States v. Hess (1888), the Court held that a mail fraud indictment was insufficient where it merely parroted the words of the statute. Rather, the Court required a more specific description of the scheme and the fraud. Fugitive disentitlement In Smith v. United States (1876) and Bonahan v. Nebraska (1887), the Court dismissed appeals pursuant to the fugitive disentitlement doctrine. Objections to grand juries In United States v. Gale (1883), the Court held that a challenge to the composition of a grand jury (specifically, the disqualification of Confederate veterans) was waived after the defendant entered a plea. Corporate officer liability In United States v. Northway (1887), the Court upheld the conviction of a bank president for a crime committed by his organization. Costs In United States ex rel. Phillips v. Gaines (1880), the Court held that it had no power to award costs in criminal cases. Diplomatic immunity In Ex parte Hitz (1884), the Court found that a Swiss consul indicted for embezzlement had no diplomatic immunity because he had resigned before the indictment. Criminal investigations Fourth Amendment Ex parte Jackson (1877) was perhaps the first criminal Fourth Amendment case to reach the Supreme Court. The Court held that a warrant was required to open mail. In Ex parte Spies (1887), the Court held that a Fourth Amendment claim was waived because the facts establishing the legality of the search did not appear in the record. Foreign extradition In United States v. Rauscher (1886), the Court vacated the conviction of a defendant who had been extradited from Great Britain to the United States, but not in conformity with the extradition treaty between the two countries. Justice Gray concurred, and Chief Justice Waite dissented. But, in Ker v. Illinois (1886), involving a defendant apprehended in Peru—a country which also had such a treaty but which had recently experienced a coup that interfered with the extradition process—the Court held that a defendant could raise no objection to the legality of his capture. Footnotes Notes References Waite Court United States Supreme Court criminal cases by Chief