Puerto Rico v. Sanchez Valle

Puerto Rico v. Sanchez Valle, 579 U.S. ___ (2016), is a criminal case that came before the Supreme Court of the United States, which considered whether Puerto Rico and the federal government of the United States are separate sovereigns for purposes of the Double Jeopardy Clause of the United States Constitution.[1]

Puerto Rico v. Sanchez Valle
Supreme Court of the United States
Argued January 13, 2016
Decided June 9, 2016
Full case nameCommonwealth of Puerto Rico, Petitioner v. Luis M. Sanchez Valle, et al.
Docket no.15-108
Citations579 U.S. ___ (more)
136 S. Ct. 1863; 195 L. Ed. 2d 179
Case history
PriorPueblo v. Sanchez Valle, 192 D.P.R. 594, 2015 TSPR 25 (Mar. 20, 2015); cert. granted, 136 S. Ct. 28 (2015).
Holding
The dual sovereignty doctrine does not apply to the U.S. territory of Puerto Rico. Therefore, the Double Jeopardy Clause bars Puerto Rico and the United States from successively prosecuting a single person for the same conduct under equivalent criminal laws.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityKagan, joined by Roberts, Kennedy, Ginsburg, Alito
ConcurrenceGinsburg, joined by Thomas
ConcurrenceThomas (in part)
DissentBreyer, joined by Sotomayor
Laws applied
U.S. Const. amend. V; Puerto Rico Arms Act of 2000

In essence, the clause establishes that an individual cannot be tried for the same offense twice under the same sovereignty.

The petitioner claimed that Puerto Rico has a different sovereignty because of its political status while others claimed that it does not, including the respondent, the Supreme Court of Puerto Rico, and the Solicitor General of the United States.[2]

In a 6–2 decision, the Court affirmed that the Double Jeopardy Clause bars Puerto Rico and the United States from successively prosecuting the same person for the same conduct under equivalent criminal laws.

The decision was affirmed 6-2 in an opinion by Justice Kagan on June 9, 2016. Justice Ginsburg filed a concurring opinion in which Justice Thomas joined. Justice Thomas filed an opinion, concurring in part and concurring in the judgment.

Justice Breyer filed a dissenting opinion in which Justice Sotomayor joined.[3]

Political implications

The argument appears to diminish the constitutional stature that the Puerto Rican government thought that it had since the Puerto Rico Federal Relations Act of 1950 and subsequent ratification of the Constitution of Puerto Rico in 1952.[4]

See also

References
  1. Liptak, Adam (January 13, 2016). "Justices Hear Case Over Puerto Rico's Sovereignty". The New York Times. Retrieved January 13, 2016.
  2. Farias, Christian (December 30, 2015). "Puerto Rico Is Up In Arms Because The Obama Administration Basically Just Called It A Colony". The Huffington Post. Retrieved January 13, 2016.
  3. "Puerto Rico v. Sanchez Valle".
  4. "Opinion analysis: Setback for Puerto Rico's independent powers (UPDATED)". June 9, 2016.
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