Definition
A "no bill" is the formal notation endorsed by a grand jury on a proposed indictment when the jury determines that the evidence presented is insufficient to charge the accused with the crime alleged. When a grand jury returns a no bill, it declines to indict — meaning the prosecution has not cleared the threshold showing of probable cause required to bring the accused to formal trial on that charge.
The phrase functions as the grand jury's rejection of the government's case at its earliest gatekeeping stage. It does not constitute an acquittal, does not bar re-presentment to a subsequent grand jury, and carries no preclusive effect on future prosecution for the same conduct in most jurisdictions.
Common Confusion
NO BILL vs. NOT GUILTY: These are frequently and seriously conflated in public discourse. A no bill is a grand jury determination made before trial, finding insufficient evidence to indict. A not guilty verdict is a trial jury determination made after full presentation of evidence, acquitting the defendant. A no bill leaves the accused exposed to future prosecution; a not guilty verdict, in most circumstances, triggers double jeopardy protections. The two proceedings operate at different procedural stages, before different bodies, under different standards.
NO BILL vs. TRUE BILL: These are mirror outcomes. A true bill is the grand jury's endorsement of an indictment — a finding that probable cause exists to proceed. A no bill is its opposite. Researchers encountering either term in historical records should confirm which outcome is recorded, as confusion between the two can invert the entire meaning of a source document.
Why It Matters in Research
The term appears almost exclusively in the context of grand jury proceedings and will surface in criminal procedure records, court dockets, and historical case files rather than in reported opinions, since a no bill typically ends proceedings before any court ruling issues.
Several research traps arise. First, the endorsed notation on historical indictment papers may use variant language — "ignoramus," "not found," "not a true bill," or "no bill" — interchangeably depending on jurisdiction and era. Bouvier and both editions of Black's confirm these are functional equivalents, but a researcher scanning original records must recognize all variants. Second, because a no bill does not bar re-presentment, the same defendant may appear in later grand jury records for the same underlying conduct. A no bill in one document does not close the chain of records. Third, in jurisdictions that have abolished or limited grand jury proceedings for non-capital felonies, the no bill as a formal procedural artifact largely disappears from modern records, replaced by preliminary hearing determinations. Researchers comparing criminal procedure across time periods must account for this structural shift.
The no bill also carries political and historical weight in certain periods. Grand jury no bills in high-profile cases — particularly in the post-Reconstruction South — have been the subject of significant historical scholarship. When researching civil rights era or Reconstruction-era criminal records, a pattern of no bills in cases involving violence against particular groups is itself historically significant, distinct from its ordinary procedural meaning.
Historical Dictionary Support
All three historical sources are in close agreement on the core definition. Black's (both editions) and Bouvier each describe the no bill as the endorsement made when the grand jury finds insufficient cause to return a true bill, and all three confirm the equivalence with "not found," "ignoramus," and "not a true bill." The agreement across sources is essentially uniform; this is not a contested or evolving term in the historical dictionaries.
The historical sources are thin on what the no bill does not do — they do not address re-presentment, double jeopardy implications, or the procedural life of the accused after a no bill issues. For those questions, researchers must move beyond dictionary definitions to treatises on criminal procedure and applicable court rules.
Bouvier's citation to "2 N. & MC. 558" points to an early South Carolina nisi prius report, indicating the term had established usage in American practice by the early nineteenth century. Neither Black's edition adds to Bouvier's substantive content; the later dictionaries appear to follow Bouvier's formulation closely.
Jurisdictional Note
Grand jury practice varies significantly. Federal courts and most states retain the grand jury for serious felonies, making the no bill a live procedural term. Some states have substantially replaced grand jury indictment with preliminary hearings, where the functional equivalent of a no bill is a magistrate's finding of no probable cause. Researchers should confirm the applicable jurisdiction's grand jury practice for the time period under study.