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Keywords

defendantstatuteappealtrial
trialobjection

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Gut v. State of Minnesota, 76 U.S. 35, 1869 WL 11595, 19 L.Ed. 573, 9 Wall. 35

Facts

In December 1866, the defendant committed a crime in Brown County, Minnesota. Following the crime, a statute was enacted allowing judges to change the venue of trials for cases involving counties attached for judicial purposes. The judge moved the trial from Brown County to Redwood County, where the defendant was later indicted for murder. The defendant was convicted after a trial in Nicollet County, leading to an appeal based on the claim that the change of venue was unconstitutional.

The act of Minnesota under consideration has no feature which brings it within either of these definitions.

Issue

Did the Minnesota statute allowing for a change of trial location from one county to another constitute an ex post facto law in violation of the Federal Constitution?

The objection to the act of Minnesota, if there be any, does not rest on the ground that it is an ex post facto law, and therefore, within the inhibition of the Federal Constitution.

Rule

A law changing the place of trial from one county to another in the same district, or even to a different district, is not an ex post facto law, even if passed after the commission of the offense.

A law changing the place of trial from one county to another county in the same district, or even to a different district from that in which the offence was committed, or the indictment found, is not an ex post facto law, though passed subsequent to the commission of the offence or the finding of the indictment.

Analysis

The court determined that the Minnesota statute did not violate the ex post facto clause because it did not change the nature of the punishment or the rules of evidence applicable to the defendant. The statute merely allowed for a change of venue within the judicial district, which was permissible under both state and federal law. The court emphasized that the defendant had the right to a jury from the district where the crime was committed, which was maintained despite the change of venue.

The ruling of the State court is conclusive upon this court, upon the point that the law in question does not violate the constitutional provision cited.

Conclusion

The Supreme Court affirmed the judgment of the lower court, ruling that the Minnesota statute was constitutional and did not violate the ex post facto clause.

JUDGMENT AFFIRMED.

Who won?

The State of Minnesota prevailed in this case, as the Supreme Court upheld the constitutionality of the statute allowing for a change of trial location.

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