United States v. Hudson and Goodwin
7 Cranch 32, 3 L.Ed. 259 (1812)
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Rule of Law:
Federal courts cannot exercise common law jurisdiction in criminal cases. For an act to be a federal crime, it must be specifically prohibited by a statute passed by Congress that also affixes a punishment and grants jurisdiction to a federal court.
Facts:
- Barzillai Hudson and George Goodwin were the publishers of a newspaper called the 'Connecticut Courant'.
- In 1806, their newspaper published an article asserting that President Thomas Jefferson and the U.S. Congress had secretly voted to give two million dollars to French Emperor Napoleon Bonaparte.
- The United States government alleged that this statement was false and was intended to defame the President and Congress.
- There was no federal statute passed by Congress that specifically made it a crime to libel the President or Congress.
Procedural Posture:
- The United States brought an indictment against Hudson and Goodwin in the U.S. Circuit Court for the District of Connecticut.
- The indictment charged Hudson and Goodwin with the common law offense of seditious libel.
- The defendants argued that the Circuit Court had no jurisdiction over the case because no federal statute had created such an offense.
- The judges of the Circuit Court were divided on the question of jurisdiction and certified the question to the United States Supreme Court.
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Issue:
Do the Circuit Courts of the United States have jurisdiction to hear criminal cases based on the common law, in the absence of a federal statute defining the offense?
Opinions:
Majority - Justice Johnson
No, the Circuit Courts of the United States do not have jurisdiction to hear criminal cases based on the common law. The powers of the federal government are limited and derived from the Constitution, meaning federal courts only possess the jurisdiction explicitly granted to them by the Constitution and by statutes enacted by Congress. While the Supreme Court's jurisdiction is constitutionally derived, all lower federal courts, such as Circuit Courts, are created by Congress and their jurisdiction is limited to what Congress confers upon them. For a federal court to preside over a criminal matter, the legislative authority must first define an act as a crime, affix a punishment to it, and declare which court has jurisdiction over the offense. The inherent powers of a court to maintain order, such as punishing for contempt, do not extend to creating or punishing common law crimes.
Analysis:
This landmark decision firmly established that there are no federal common law crimes in the United States. It solidifies the principle of separation of powers, ensuring that only the legislative branch (Congress) can define criminal conduct at the federal level, not the judiciary. The case is a cornerstone of federal criminal jurisprudence, creating a clear distinction between the limited jurisdiction of federal courts and the broader, general jurisdiction often held by state courts, which may recognize common law offenses. By rejecting federal common law crimes, the Court reinforced the idea that the federal government is one of enumerated, not inherent, powers.
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