Puerto Rico v. Sanchez Valle

Background

Two men in Puerto Rico sold guns to an undercover police officer. Commonwealth prosecutors charged them under Puerto Rico’s gun law, and federal prosecutors later charged them under U.S. gun statutes for the same conduct. After pleading guilty in federal court, the men asked Puerto Rico courts to dismiss the island’s charges as barred by the Double Jeopardy Clause, and the Puerto Rico Supreme Court agreed. The U.S. Supreme Court took the case to decide whether both governments may prosecute the same person for the same act.

Reasoning

The Court explained that its longstanding dual-sovereignty rule asks only whether the two prosecutors draw their authority from distinct, historical sources. Because Puerto Rico became a U.S. territory in 1898 and Congress authorized and approved Puerto Rico’s 1952 constitution under Public Law 600, the Court concluded that the ultimate source of Puerto Rico’s power to prosecute traces back to Congress. The Court therefore held that Puerto Rico and the United States are not separate sovereigns for double jeopardy purposes, and affirmed the Puerto Rico Supreme Court’s judgment dismissing the Commonwealth prosecutions.

Real world impact

The decision prevents both the federal government and Puerto Rico from successively prosecuting the same person for identical criminal conduct arising from the same acts. Prosecutors in Puerto Rico and the federal government must choose which government will bring charges in overlapping cases. The Court noted the ruling follows historical-source precedent and is not a final review of Puerto Rico’s broader political status.

Dissents or concurrances

Justice Ginsburg (joined by Justice Thomas) urged broader reconsideration of the separate-sovereigns doctrine; Justice Breyer (joined by Justice Sotomayor) dissented, arguing Puerto Rico’s 1952 constitution made it an independent source of prosecutorial power.