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Puerto Rico v. Sanchez Valle

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2016 United States Supreme Court case
Puerto Rico v. Sanchez Valle
Argued January 13, 2016
Decided June 9, 2016
Full case nameCommonwealth of Puerto Rico, Petitioner v. Luis M. Sanchez Valle, et al.
Docket no.15-108
Citations579U.S. 59 (more)
136 S. Ct. 1863; 195L. Ed. 2d 179
Case history
PriorPueblo v. Sanchez Valle, 192 D.P.R. 594, 2015TSPR 25 (Mar. 20, 2015);cert. granted, 136 S. Ct. 28 (2015).
Holding
Thedual sovereignty doctrine does not apply to the U.S. territory of Puerto Rico. Therefore, theDouble Jeopardy Clause bars Puerto Rico and the United States from successively prosecuting a single person for the same conduct under equivalent criminal laws.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityKagan, joined by Roberts, Kennedy, Ginsburg, Alito
ConcurrenceGinsburg, joined by Thomas
ConcurrenceThomas (in part)
DissentBreyer, joined by Sotomayor
Laws applied
U.S. Const. amend. V; Puerto Rico Arms Act of 2000

Puerto Rico v. Sanchez Valle, 579 U.S. 59 (2016), is acriminal case that came before theSupreme Court of the United States, which considered whetherPuerto Rico and thefederal government of the United States are separate sovereigns for purposes of theDouble Jeopardy Clause of theUnited States Constitution.[1]

In essence, the clause establishes that an individualcannot be tried for the same offense twice under the same sovereignty.

The petitioner claimed that Puerto Rico has a different sovereignty because ofits political status while others claimed that it does not, including the respondent, theSupreme Court of Puerto Rico, and theSolicitor General of the United States.[2]

In a 6–2 decision, the Court affirmed that the Double Jeopardy Clause bars Puerto Rico and the United States from successively prosecuting the same person for the same conduct under equivalent criminal laws.

The decision was affirmed 6-2 in an opinion by JusticeKagan on June 9, 2016. JusticeGinsburg filed a concurring opinion in which JusticeThomas joined. Justice Thomas filed an opinion, concurring in part and concurring in the judgment.

JusticeBreyer filed a dissenting opinion in which JusticeSotomayor joined.[3]

Political implications

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The argument appears to diminish the independent authority to prosecute criminal laws that thegovernment of Puerto Rico thought that it had since thePuerto Rico Federal Relations Act of 1950 and subsequent ratification of theConstitution of Puerto Rico in 1952.[4]

See also

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References

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  1. ^Liptak, Adam (January 13, 2016)."Justices Hear Case Over Puerto Rico's Sovereignty".The New York Times. RetrievedJanuary 13, 2016.
  2. ^Farias, Christian (December 30, 2015)."Puerto Rico Is Up In Arms Because The Obama Administration Basically Just Called It A Colony".The Huffington Post. RetrievedJanuary 13, 2016.
  3. ^"Puerto Rico v. Sanchez Valle".
  4. ^"Opinion analysis: Setback for Puerto Rico's independent powers (UPDATED)". June 9, 2016.

External links

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Grand Jury Clause
Meaning of "same offense"
After acquittal
After conviction
After mistrial
Multiple punishment
Dual sovereignty doctrine
Other
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