Adams v. United States

Background

Three soldiers were convicted in federal court for the rape of a civilian woman that occurred inside Camp Claiborne, a military camp on land the United States had acquired. The dispute turned on whether the federal court could enforce federal criminal laws there because the government had not filed the formal notice of jurisdiction acceptance required by a 1940 law (40 U.S.C. §255).

Reasoning

The Court considered whether the 1940 Act means the United States must file a formal notice to obtain any kind of federal jurisdiction—exclusive, partial, or concurrent—over land acquired after the law. The Court relied on the Act’s text and on the consistent views of several federal agencies that the Act requires formal acceptance. Because no notice had been filed before the offense, the Court held the federal court lacked authority to try the soldiers under the federal criminal statutes charged.

Real world impact

The decision prevents federal courts from enforcing federal criminal laws on newly acquired federal land unless the government follows the 1940 Act’s formal acceptance procedure. That means offenses occurring on such land may remain subject to state authority until the United States formally accepts jurisdiction. The Court answered the certified questions: yes, the Act has that effect, and no, the District Court did not have jurisdiction to try these defendants.