United States v. Sharpnack

Background

The dispute was between the United States and a man named Sharpnack. He was indicted for sex crimes involving two boys allegedly committed in 1955 at Randolph Air Force Base, a federal military base in Texas. He was charged under the federal Assimilative Crimes Act, 18 U.S.C. § 13, which in turn relied on Texas laws (Articles 535b and 535c) enacted in 1950. The district court dismissed the indictment, saying Congress could not adopt state laws enacted after the federal Act, and the Government appealed to the Supreme Court.

Reasoning

The Court asked whether Congress could constitutionally make state criminal laws enacted later enforceable inside federal enclaves. The majority pointed to a long history of Congress adopting local laws for enclaves since 1825, repeated reenactments, and the 1948 statute’s language saying state laws in force at the time of the act apply. The Court held that this practice is a valid use of Congress’s power over federal property, that Congress can exclude particular state laws if it wishes, and reversed the district court’s dismissal.

Real world impact

As a result, crimes on federal land such as military bases can be punished under state laws that are in effect when the conduct occurs, even if those state laws were passed after the federal assimilation statute. State changes to criminal rules will generally take effect on federal enclaves unless Congress acts to exclude them. The opinion did not resolve cases where a state law might conflict with a specific federal criminal statute or federal policy.

Dissents or concurrances

Justice Douglas, joined by Justice Black, dissented. He argued that treating later state laws as federal law improperly hands lawmaking to the States and warned this could allow controversial state rules to become federal crimes without Congress’s direct choice.