Puerto Rico v. Sanchez Valle
136 S. Ct. 1863
| SCOTUS | 2016Background
- Puerto Rico was ceded by Spain to the United States in 1898; Congress initially governed the island under the Territory Clause and later enacted organic legislation granting increasing local autonomy.
- In 1950–1952 Congress authorized and approved a constitution for Puerto Rico (Public Law 600), creating the Commonwealth of Puerto Rico exercising broad self-government under that constitution but with congressional authorization and final approval of the charter.
- Two defendants (Sánchez Valle and Gómez Vázquez) sold firearms and were prosecuted federally (they pleaded guilty) and also indicted by Commonwealth prosecutors under a Puerto Rico Arms Act; Commonwealth courts dismissed the local charges on double jeopardy grounds, the Puerto Rico Court of Appeals reversed, and the Puerto Rico Supreme Court held the Commonwealth prosecutions barred.
- The Supreme Court granted certiorari to decide whether Puerto Rico and the United States are separate sovereigns under the Double Jeopardy Clause (i.e., whether successive prosecutions by both are permitted).
- The central legal question: does Puerto Rico’s prosecutorial authority derive from an independent ultimate source from the United States (per the Court’s historical "ultimate source" test), or does Congress remain the ultimate source so that dual prosecutions are barred?
Issues
| Issue | Plaintiff's Argument (Puerto Rico) | Defendant's Argument (United States) | Held |
|---|---|---|---|
| Whether Puerto Rico and the U.S. are separate sovereigns for double jeopardy purposes | Puerto Rico: After Public Law 600 and the 1952 Constitution, prosecutorial power flows from the people of Puerto Rico and its constitution—an independent source | U.S.: Puerto Rico’s prosecutorial power ultimately derives from Congress because Congress authorized/approved the constitution; territories’ powers are delegations from Congress | Held: Not separate sovereigns. Puerto Rico’s ultimate source of prosecutorial power is Congress; double jeopardy bars successive prosecutions by both |
| Proper test for "sovereignty" under Double Jeopardy | Puerto Rico: Emphasize functional autonomy and modern self-governance as dispositive | U.S./Majority: Apply historical "ultimate source" test—look to origin of prosecutorial power, not present autonomy | Held: Use historical "ultimate source" test; functional autonomy is irrelevant to dual-sovereignty analysis |
Key Cases Cited
- United States v. Wheeler, 435 U.S. 313 (historical "ultimate source" test for tribal/state sovereignty under Double Jeopardy)
- United States v. Lanza, 260 U.S. 377 (permitting successive prosecutions by separate sovereigns)
- Heath v. Alabama, 474 U.S. 82 (same-act violating laws of two sovereigns constitutes two offenses)
- Waller v. Florida, 397 U.S. 387 (municipalities are not separate sovereigns from States for double jeopardy)
- Grafton v. United States, 206 U.S. 333 (territories derive prosecutorial authority from federal government)
- Puerto Rico v. Shell Co., 302 U.S. 253 (territorial and federal laws emanate from the same sovereignty)
- Abbate v. United States, 359 U.S. 187 (States are separate sovereigns from the federal government)
- Bartkus v. Illinois, 359 U.S. 121 (same; dual-sovereignty principles)
- Santa Clara Pueblo v. Martinez, 436 U.S. 49 (tribal sovereignty pre-existed federal authority; tribes treated as separate sovereigns)
- Coyle v. Smith, 221 U.S. 559 (new States admitted to Union possess powers equal to original States; equal footing doctrine)