United States v. Hudson and Goodwin, 11 U.S. (7 Cranch) 32 (1812), was a case in which the United States Supreme Court held that Congress must first enact a constitutional law criminalizing an activity, attach a penalty, and give the federal courts jurisdiction over the offense in order for the court to render a conviction.
On certiorari from the Circuit Court for the District of Connecticut
Holding
The lower federal courts have no jurisdiction in criminal cases unless Congress has designated an act to be a crime, attached a penalty, and granted jurisdiction.
Barzillai Hudson and George Goodwin, the defendants in the case, were charged with a libel on the President and Congress, and of having accused them of secretly voting to give Napoleon Bonaparte $2 million to make a treaty with Spain. The circuit court was divided on whether it could exercise common law jurisdiction over such cases.
Decisionedit
Justice William Johnson, Jr. delivered the opinion of the Court. He first explained that the federal government is one of limited powers, as set forth in the Constitution. Furthermore, only the jurisdiction of the Supreme Court was explicitly defined in Article III of the U.S. Constitution. Since the lower federal courts were created by Congress with the Judiciary Act of 1789, their jurisdiction had to be defined by Congress. Therefore, the Court reasoned that since Congress has the power to create such courts, the principles of limited government militate in favor of limiting their jurisdiction to specific acts specified by Congress.
The Court held, "The legislative authority of the Union must first make an act a crime, affix a punishment to it, and declare the Court that shall have jurisdiction of the offence." In dicta, he also mentioned an exception to the general rule. Courts have some implied powers, such as punishing litigants for contumacy (contempt of court) and enforcing court orders.
Impactedit
The case effectively closed the door on the lower federal courts' powers to convict defendants for common law crimes and mandated Congress to define criminal jurisdiction specifically, through legislation.
Gary D. Rowe, The Sound of Silence: United States v. Hudson & Goodwin, the Jeffersonian Ascendancy, and the Abolition of Federal Common Law Crimes, 101 Yale L.J. 919 (1992).
External linksedit
Text of United States v. Hudson and Goodwin, 11U.S. (7 Cranch) 32 (1812) is available from:CourtListenerFindlawJustiaLibrary of CongressOpenJurist
Page from History of the U.S. Supreme Court website, explaining the background and context of the case (scroll down to find this case).
January 01, 1970
united, states, hudson, goodwin, cranch, 1812, case, which, united, states, supreme, court, held, that, congress, must, first, enact, constitutional, criminalizing, activity, attach, penalty, give, federal, courts, jurisdiction, over, offense, order, court, re. United States v Hudson and Goodwin 11 U S 7 Cranch 32 1812 was a case in which the United States Supreme Court held that Congress must first enact a constitutional law criminalizing an activity attach a penalty and give the federal courts jurisdiction over the offense in order for the court to render a conviction United States v Hudson and GoodwinSupreme Court of the United StatesDecided February 13 1812Full case nameUnited States v Barzillai Hudson and George GoodwinCitations11 U S 32 more 11 Cranch 32 3 L Ed 259 1812 U S LEXIS 365Case historyPriorOn certiorari from the Circuit Court for the District of ConnecticutHoldingThe lower federal courts have no jurisdiction in criminal cases unless Congress has designated an act to be a crime attached a penalty and granted jurisdiction Court membershipChief Justice John Marshall Associate Justices Bushrod Washington William JohnsonH Brockholst Livingston Thomas ToddGabriel Duvall Joseph StoryCase opinionMajorityJohnson joined by Marshall Livingston Todd Duvall StoryWashington took no part in the consideration or decision of the case Laws appliedU S Const art III Contents 1 Facts 2 Decision 3 Impact 4 See also 5 References 6 External linksFacts editBarzillai Hudson and George Goodwin the defendants in the case were charged with a libel on the President and Congress and of having accused them of secretly voting to give Napoleon Bonaparte 2 million to make a treaty with Spain The circuit court was divided on whether it could exercise common law jurisdiction over such cases Decision editJustice William Johnson Jr delivered the opinion of the Court He first explained that the federal government is one of limited powers as set forth in the Constitution Furthermore only the jurisdiction of the Supreme Court was explicitly defined in Article III of the U S Constitution Since the lower federal courts were created by Congress with the Judiciary Act of 1789 their jurisdiction had to be defined by Congress Therefore the Court reasoned that since Congress has the power to create such courts the principles of limited government militate in favor of limiting their jurisdiction to specific acts specified by Congress The Court held The legislative authority of the Union must first make an act a crime affix a punishment to it and declare the Court that shall have jurisdiction of the offence In dicta he also mentioned an exception to the general rule Courts have some implied powers such as punishing litigants for contumacy contempt of court and enforcing court orders Impact editThe case effectively closed the door on the lower federal courts powers to convict defendants for common law crimes and mandated Congress to define criminal jurisdiction specifically through legislation See also editList of United States Supreme Court cases volume 11References editGary D Rowe The Sound of Silence United States v Hudson amp Goodwin the Jeffersonian Ascendancy and the Abolition of Federal Common Law Crimes 101 Yale L J 919 1992 External links editText of United States v Hudson and Goodwin 11 U S 7 Cranch 32 1812 is available from CourtListener Findlaw Justia Library of Congress OpenJurist Page from History of the U S Supreme Court website explaining the background and context of the case scroll down to find this case Retrieved from https en wikipedia org w index php title United States v Hudson amp oldid 1175151530, wikipedia, wiki, book, books, library,
