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Keywords

defendantjurisdictionappealtrialpleacriminal lawdouble jeopardyprosecutor

defendantdouble jeopardyprosecutorrespondent

Related Cases

Commonwealth of Puerto Rico v. Sanchez Valle, 579 U.S. 59, 136 S.Ct. 1863, 195 L.Ed.2d 179, 84 USLW 4376, 16 Cal. Daily Op. Serv. 5958, 2016 Daily Journal D.A.R. 5605, 26 Fla. L. Weekly Fed. S 212

Facts

Luis Sánchez Valle and Jaime Gómez Vázquez were indicted in Puerto Rico for selling firearms without a permit after they sold guns to an undercover officer. While these charges were pending, they were also indicted federally for similar offenses based on the same transactions. Both defendants pleaded guilty to the federal charges and subsequently moved to dismiss the Commonwealth charges on double jeopardy grounds, arguing that the two prosecutions were for the same offense. The trial courts dismissed the charges, but the Puerto Rico Court of Appeals reversed this decision before the Supreme Court of Puerto Rico ultimately affirmed the trial courts' dismissals.

Respondents Luis Sánchez Valle and Jaime Gómez Vázquez each sold a gun to an undercover police officer. Puerto Rican prosecutors indicted them for illegally selling firearms in violation of the Puerto Rico Arms Act of 2000.

Issue

Whether the Double Jeopardy Clause bars the Federal Government and Puerto Rico from successively prosecuting a defendant on like charges for the same conduct.

We must decide if, under that test, Puerto Rico and the United States may successively prosecute a single defendant for the same criminal conduct.

Rule

The Double Jeopardy Clause prohibits more than one prosecution for the same offense, but under the dual-sovereignty doctrine, successive prosecutions are permissible if they are brought by separate sovereigns. The key question is whether the prosecutorial powers of the two jurisdictions derive from independent sources.

The Double Jeopardy Clause prohibits more than one prosecution for the 'same offence.' But under what is known as the dual-sovereignty doctrine, a single act gives rise to distinct offenses—and thus may subject a person to successive prosecutions—if it violates the laws of separate sovereigns.

Analysis

The U.S. Supreme Court analyzed the historical context of Puerto Rico's prosecutorial authority, concluding that both Puerto Rico and the Federal Government derive their prosecutorial powers from the same ultimate source: the U.S. Congress. The Court emphasized that the dual-sovereignty doctrine does not apply because Puerto Rico's power to prosecute does not predate its association with the United States, and thus, the Commonwealth cannot be considered a separate sovereign for double jeopardy purposes.

On this settled approach, Puerto Rico cannot benefit from our dual-sovereignty doctrine. For starters, no one argues that when the United States gained possession of Puerto Rico, its people possessed independent prosecutorial power, in the way that the States or tribes did upon becoming part of this country.

Conclusion

The Supreme Court held that 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, affirming the decision of the Puerto Rico Supreme Court.

We hold they may not, because the oldest roots of Puerto Rico's power to prosecute lie in federal soil.

Who won?

The prevailing party was the defendants, Luis Sánchez Valle and Jaime Gómez Vázquez, as the Supreme Court affirmed the dismissal of the Commonwealth charges based on double jeopardy grounds.

The Supreme Court of Puerto Rico granted review and held that Puerto Rico's gun sale prosecutions violated the Double Jeopardy Clause.

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