United States v. Jackalow

United States v. Jackalow
Supreme Court of the United States
Argued March 18, 1862 Decided March 24, 1862
Full case name	United States v. Jackalow
Citations	66 U.S. 484 (more) 1 Black 484; 17 L. Ed. 225; 1861 U.S. LEXIS 502
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
Chief Justice Roger B. Taney Associate Justices James M. Wayne · John Catron Samuel Nelson · Robert C. Grier Nathan Clifford · Noah H. Swayne
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.