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Law School Case Brief

Puerto Rico v. Sánchez Valle - 136 S. Ct. 1863 (2016)


The Double Jeopardy Clause of the Fifth Amendment 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. To determine whether two prosecuting authorities are different sovereigns for double jeopardy purposes, the Supreme Court of the United States asks a narrow, historically focused question. The inquiry does not turn, as the term sovereignty sometimes suggests, on the degree to which the second entity is autonomous from the first or sets its own political course. Rather, the issue is only whether the prosecutorial powers of the two jurisdictions have independent origins, or, said conversely, whether those powers derive from the same ultimate source.


Respondents Luis Sanchez Valle and Jaime Gomez Vazquez 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. While those charges were pending, federal grand juries also indicted them, based on the same transactions, for violations of analogous United States gun trafficking statutes. Both defendants pleaded guilty to the federal charges and moved to dismiss the pending Commonwealth charges on Double Jeopardy grounds. The trial court in each case dismissed the charges, rejecting the prosecutors' arguments that Puerto Rico and the United States were separate sovereigns for double jeopardy purposes and thus could bring successive prosecutions against each defendant. The Court of Appeals of Puerto Rico consolidated the cases and reversed. The Supreme Court of Puerto Rico granted review and held, in line with the trial court, that Puerto Rico's gun sale prosecutions violated the Double Jeopardy Clause. The Commonwealth was granted a writ of certiorari.


Did the Double Jeopardy Clause bar Puerto Rico from prosecuting defendants under Commonwealth gun-sale laws?




The Supreme Court of the United States affirmed the judgment from the Supreme Court of Puerto Rico. The Court held that the dismissal of the pending Commonwealth charges was proper under the dual-sovereignty carve-out from the Double Jeopardy Clause, U.S. Const. amend. V, because the Double Jeopardy Clause barred both Puerto Rico and the United States from prosecuting a single person for the same conduct under equivalent criminal laws. The Commonwealth and the United States were not separate sovereigns because the ultimate source of Puerto Rico's prosecutorial power was the federal government.

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