United States v. Sharon Rose

Appellant Rose was called as a witness for the prosecution in a criminal trial in the district court for the District of Oregon. On the date scheduled for trial, appellant notified the court that she would invoke her Fifth Amendment privilege against compelled self-incrimination. In an in camera proceeding, the trial court upheld her claim of privilege and granted the prosecution a one-day continuance to seek an immunity order.

The trial began the next day. Because the government had not yet received written authorization to grant immunity, the prosecution, on instructions from the bench,…