United States v. Lanza
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| United States v. Lanza | |
| Reference: 260 U.S. 377 | |
| Term: 1922 | |
| Important Dates | |
| Argued: November 23, 1922 Decided: December 11, 1922 | |
| Outcome | |
| United States District Court for the Western District of Washington reversed | |
| Majority | |
| William Howard Taft | |
United States v. Lanza is a case decided on December 11, 1922, by the United States Supreme Court holding that the Double Jeopardy Clause of the U.S. Constitution does not apply when two separate sovereignties were impacted by the offense. The case concerned whether the federal government and a state government could seek consecutive prosecutions of an individual for the same offense. The Supreme Court reversed the decision of the United States District Court for the Western District of Washington, which established the dual sovereignty doctrine.[1]
Why it matters: The Supreme Court's decision in this case established the dual sovereignty doctrine, which grants authority to the federal government and state governments as separate sovereignties to seek consecutive prosecutions for an offense. To read more about the impact of United States v. Lanza click here.
Background
Individuals were indicted in April 1920 by both a federal court and a Washington state court for manufacturing, transporting, and possessing liquor, which violated the National Prohibition Act and a Washington state statute. The federal court additionally charged the defendants with having a still and the materials necessary to manufacture the liquor. The defendants argued that the consecutive punishments were for the same crime and violated their constitutional protection against double jeopardy under the Fifth Amendment. As a result, the United States District Court for the Western District of Washington dismissed all five counts. A writ of error was filed with the Supreme Court to review the district court's decision.[1]
Oral argument
Oral argument was held on November 23, 1922. The case was decided on December 11, 1922.[1]
Decision
The Supreme Court decided unanimously to reverse the decision of the United States District Court for the Western District of Washington. Chief Justice William Howard Taft delivered the opinion of the court.[1]
Opinions
Opinion of the court
Chief Justice William Howard Taft, writing for the court, argued that the Eighteenth Amendment of the U.S. Constitution established a national policy to prohibit the manufacture, sale, and transportation of liquors that was to be implemented and enforced by both federal and state laws. As a result, Taft contended that the federal government and the state of Washington both had jurisdiction to prosecute the defendants in the case.[1]
| “ | The amendment was adopted for the purpose of establishing prohibition as a national policy reaching every part of the United States and affecting transactions which are essentially local or intrastate, as well as those pertaining to interstate or foreign commerce. The second section means that power to take legislative measures to make the policy effective shall exist in Congress in respect of the territorial limits of the United States, and at the same time the like power of the several states within their territorial limits shall not cease to exist. Each state, as also Congress, may exercise an independent judgment in selecting and shaping measures to enforce prohibition. Such as are adopted by Congress become laws of the United States, and such as are adopted by a state become laws of that state. They may vary in many particulars, including the penalties prescribed, but this is an inseparable incident of independent legislative action in distinct jurisdictions. [2] | ” |
| —William Howard Taft, majority opinion in United States v. Lanza[1] | ||
Taft posited that the federal and state government with jurisdiction in this case were two separate sovereignties. Each sovereignty had the authority to enact laws to enforce prohibition. The offense that occurred was in violation of both federal law and state law and therefore violated the peace and dignity of both sovereignties, which allowed them to each respond to the offense.[1]
| “ | We have here two sovereignties, deriving power from different sources, capable of dealing with the same subject matter within the same territory. Each may, without interference by the other, enact laws to secure prohibition, with the limitation that no legislation can give validity to acts prohibited by the amendment. Each government, in determining what shall be an offense against its peace and dignity, is exercising its own sovereignty, not that of the other.
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| —William Howard Taft, majority opinion in United States v. Lanza[1] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Dual sovereignty doctrine
United States v. Lanza established the dual sovereignty doctrine, which refers to the authority of separate sovereignties to pursue the same case in criminal court when the offense committed impacts both jurisdictions without violating the Double Jeopardy Clause of the Fifth Amendment of the U.S. Constitution. The doctrine was established in this case by allowing the federal government and the state of Washington to consecutively prosecute individuals for the same crime. The decision in this case determined that since each sovereignty had its own laws outlawing the offense, they both had jurisdiction to pursue the case in criminal court.[1]
The dual sovereignty doctrine was later expanded by Heath v. Alabama (1985) to allow multiple states to pursue consecutive prosecutions against an individual for the same crime when the offense occurs within multiple states' jurisdictions.
See also
- The Taft Court
- Supreme Court of the United States
- History of the Supreme Court
- Federalism
- Dual sovereignty doctrine
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
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