Puerto Rico v. Rubert Hermanos, Inc.

Background

The Government of Puerto Rico, through its Attorney General, brought a quo warranto action in the island’s Supreme Court against a corporation organized under Puerto Rico law in 1927. The suit alleged the corporation violated a Congressional rule, first declared in 1900 and continued in the 1917 Organic Act, that corporations engaged in agriculture may not own or control more than 500 acres. In 1935 Puerto Rico’s legislature passed two acts giving the island Supreme Court jurisdiction to bring such quo warranto proceedings and authorizing confiscation or sale of unlawfully held real estate. A federal Court of Appeals reversed the Puerto Rico Supreme Court, and the case was reviewed here.

Reasoning

The central question was whether Puerto Rico’s legislature could add local enforcement measures to Congress’s land-ownership restriction. The Court focused on the broad legislative powers Congress gave Puerto Rico in the Organic Act and concluded the island’s legislature could provide local remedies. The Justices also held that §39 of the Organic Act is not a “law of the United States” for purposes of a federal statute that reserves certain penalty cases to U.S. courts, so that local courts are not excluded. On those grounds the Supreme Court reversed the federal appeals court and affirmed the Puerto Rico Supreme Court’s authority to proceed.

Real world impact

The decision lets Puerto Rico use its own courts to enforce the five-hundred-acre limit and to seek forfeiture, sale, or other relief against corporations holding land in violation of that limit. The ruling affirms local control over how Congress’s territorial policy is put into effect and affects corporations, local authorities, and communities dependent on island land.