United States v. Hudson and Goodwin
Encyclopedia
United States v. Hudson and Goodwin, 11 U.S. 32
(1812), was a case in which the United States Supreme Court
held that Congress
must first enact a 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.
in this case, were charged with a libel on the President
and Congress, having accused them of secretly voting to give Napoleon Bonaparte $2 million to make a treaty with Spain
. The Circuit Court
was divided on the question of whether they could exercise common law
jurisdiction over such cases.
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 those courts' jurisdiction to specific acts specified by Congress. The Court held that "[t]he 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."
Justice Johnson, in dicta
, also mentioned an exception to this general rule—that courts do have some implied powers; for example, to punish litigants for contumacy
(contempt of court
) and enforcement of court orders.
. Thus, the court essentially introduced the legal concept of nulla poena sine lege
into federal jurisprudence.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1812), was a case in which the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
must first enact a law criminalizing an activity, attach a penalty, and give the federal courts jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
over the offense in order for the court to render a conviction.
Facts
Barzillai Hudson and George Goodwin, the defendantsDefendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
in this case, were charged with a libel on the President
President of the United States
The President of the United States of America is the head of state and head of government of the United States. The president leads the executive branch of the federal government and is the commander-in-chief of the United States Armed Forces....
and Congress, having accused them of secretly voting to give Napoleon Bonaparte $2 million to make a treaty with Spain
Spain
Spain , officially the Kingdom of Spain languages]] under the European Charter for Regional or Minority Languages. In each of these, Spain's official name is as follows:;;;;;;), is a country and member state of the European Union located in southwestern Europe on the Iberian Peninsula...
. The Circuit Court
United States circuit court
The United States circuit courts were the original intermediate level courts of the United States federal court system. They were established by the Judiciary Act of 1789. They had trial court jurisdiction over civil suits of diversity jurisdiction and major federal crimes. They also had appellate...
was divided on the question of whether they could exercise common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
jurisdiction over such cases.
Decision
Justice William Johnson, Jr.William Johnson (judge)
William Johnson was a state legislator and judge in South Carolina, and an Associate Justice of the United States Supreme Court from 1804 to his death in 1834.-Youth and early career:...
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
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
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
Judiciary Act of 1789
The United States Judiciary Act of 1789 was a landmark statute adopted on September 24, 1789 in the first session of the First United States Congress establishing the U.S. federal judiciary...
, 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 those courts' jurisdiction to specific acts specified by Congress. The Court held that "[t]he 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."
Justice Johnson, in dicta
Obiter dictum
Obiter dictum is Latin for a statement "said in passing". An obiter dictum is a remark or observation made by a judge that, although included in the body of the court's opinion, does not form a necessary part of the court's decision...
, also mentioned an exception to this general rule—that courts do have some implied powers; for example, to punish litigants for contumacy
Contumacy
Contumacy is a stubborn refusal to obey authority or, particularly in law, the wilful contempt of the order or summons of a court The term is derived from the Latin word contumacia, meaning firmness or stubbornness....
(contempt of court
Contempt of court
Contempt of court is a court order which, in the context of a court trial or hearing, declares a person or organization to have disobeyed or been disrespectful of the court's authority...
) and enforcement of court orders.
Impact
This case effectively closed the door on the lower federal courts' powers to try and convict defendants for common law crimes, and mandated that Congress specifically define their criminal jurisdiction through legislationLegislation
Legislation is law which has been promulgated by a legislature or other governing body, or the process of making it...
. Thus, the court essentially introduced the legal concept of nulla poena sine lege
Nulla poena sine lege
Nulla poena sine lege is a legal principle, requiring that one cannot be punished for doing something that is not prohibited by law. This principle is accepted as just and upheld by the penal codes of constitutional states, including virtually all modern democracies...
into federal jurisprudence.
External links
Additional resources
- Page from History of the U.S. Supreme Court website, explaining the background and context of the case (scroll down to find this case).