| United States v. Jackalow | |
|---|---|
 | |
| Argued March 18, 1862 Decided March 24, 1862 | |
| Full case name | United States v. Jackalow |
| Citations | 66 U.S. 484 (more) |
| Case history | |
| Prior | Certificate of division from conviction in C.C.D.N.J. |
| Subsequent | Nol pros motion granted |
| Holding | |
| Under the Venue and Vicinage clauses, although the description of a U.S. state boundary is a question of law for the judge, the ascertainment and application of that boundary is a question of fact for the jury. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Nelson, joined by unanimous |
| Laws applied | |
| U.S. Const. art. III, § 2, cl. 3; U.S. Const. amend. VI | |
United States v. Jackalow, 66 U.S. (1 Black) 484 (1862), is a U.S. Supreme Court case interpreting the Venue and Vicinage clauses of the United States Constitution. It was an "unusual criminal case"[1] and one of the few constitutional criminal cases from the Taney Court. Jackalow, a mariner from the Ryukyu Kingdom, was suspected of the robbery and murder of the captain of the sloop Spray, Jonathan Leete, and Jonathan's brother Elijah, while the ship was at sea. He was convicted of robbery in the Long Island Sound, but as there was disagreement over the question of jurisdiction between the two judges who heard the post-trial motion (Judge Mahlon Dickerson and Supreme Court Justice Robert Cooper Grier), the case was referred to the Supreme Court by certificate of division.
The Supreme Court directed the circuit court for the District of New Jersey to grant Jackalow a new trial. The Court held that while the trial court should determine the description of the boundaries of New York and Connecticut, the ascertainment of their actual boundaries, and the application of those boundaries to the crime in question, should have been a question of fact for the jury. Jackalow was not retried and was released.
The trial attracted significant media interest. According to The New York Times, "every part in and near the Court room was crowded during the trial."[2] The case is viewed as historically significant because even though it occurred during the American Civil War, the federal courts focused on proper legal procedure and jurisprudence in a case unrelated to the war.
- ^ Lender (2006), p. 100.
- ^ Cite error: The named reference
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