United States v. Hudson and Goodwin

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Brief Fact Summary.

Hudson and Goodwin (Defendants) were indicted for newspaper libel against the President and Congress. They argued that the United States circuit courts had no common law jurisdiction in libel cases.

Synopsis of Rule of Law.

United States courts do not have common law jurisdiction in criminal cases.

Points of Law - Legal Principles in this Case for Law Students.

To fine for contempt, imprison for contumacy, enforce the observance of order, &c., are powers which cannot be dispensed with in a court, because they are necessary to the exercise of all others: and so far our courts, no doubt, possess powers not immediately derived from statute.

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Facts.

Defendants were indicted for libel against the President and Congress. Defendants argued that the federal circuit courts did not have common law jurisdiction in libel cases. The case was certified to the United States Supreme Court.

Issue.

Do United States courts have common law jurisdiction in criminal cases?

Held.

(Johnson, J.) No. United States courts do not have common law jurisdiction in criminal cases. The authorities not granted to the federal government by the states are reserved to the states. The only constitutionally created court is the Supreme Court. All other federal courts only possess the jurisdiction given to them by the legislature. The federal legislature must first make an act a crime, determine the punishment, and grant federal courts jurisdiction to hear the crime. That has not happened here

Discussion.

This case established that the federal courts only have jurisdiction over crimes defined by federal statute.

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