United States v. Wilson

Background

A union official — the business manager of a local union — was tried for converting union funds to pay part of his daughter’s wedding. The FBI investigated years earlier, but the Government waited about 16 months before indicting three days before the statute of limitations ran. A jury found him guilty, but the trial judge later dismissed the indictment, saying the earlier delay had unfairly harmed the defendant’s ability to mount a defense. The Court of Appeals refused to hear the Government’s appeal, saying the Double Jeopardy Clause barred review; the United States asked the Supreme Court to decide.

Reasoning

The central question was whether the Constitution prevents the Government from appealing a judge’s postverdict ruling that dismisses charges. The Court said double jeopardy protects people from being tried twice, but it does not automatically block every Government appeal. When a jury has returned a guilty verdict, correcting a judge’s legal ruling on appeal will not necessarily force a second trial. The Court relied on the close connection between the policy against multiple prosecutions and the question whether an appeal would expose the defendant to another trial, and it concluded appeals are permissible where they do not create that risk.

Real world impact

The decision allows prosecutors to appeal certain trial-court rulings made after a guilty verdict without violating the Double Jeopardy Clause. If the Government wins on appeal, the case can return to the trial court for further proceedings; if the defendant wins, the dismissal stands and no second prosecution is allowed.

Dissents or concurrances

A dissent argued that when a judge’s postverdict dismissal is based on evidence presented at trial and functions like an acquittal, allowing appellate review would improperly expose defendants to a second factual judgment and should be barred.