In Re Vidal
Headline: Court denies review of a military-created tribunal in Puerto Rico and refuses a Supreme Court petition, leaving a new federal district court to handle the dispute over Guayama municipal officials.
Holding: The Court denied leave to file a Supreme Court petition to review a military tribunal’s proceedings in Puerto Rico, holding it cannot use certiorari and noting Congress replaced the tribunal with a federal district court.
- Prevents Supreme Court review of the Puerto Rico military tribunal’s proceedings.
- Transfers pending cases and records to a new United States District Court.
- Leaves municipal officers in Guayama to seek relief in the federal district court.
Summary
Background
An application asked for permission to file a Supreme Court petition to review proceedings of a tribunal set up in Puerto Rico by General Order No. 88 under Brigadier-General Davis, then the military commander. The tribunal heard a quo warranto action aiming to remove Vidal and others from municipal offices in the town of Guayama. The application was submitted April 23, 1900, and an opposition brief was filed April 30. The Court cited Section 716 of the Revised Statutes but said that did not allow certiorari review of military tribunals.
Reasoning
The central question was whether the Supreme Court could use its special writ (certiorari) or inherent power to review decisions of a military tribunal established by military authority. The Court held it could not. It explained that such military tribunals are not courts "with jurisdiction in law or equity" under the Constitution’s Article III language and therefore certiorari cannot be used to review them. The Court also noted that Congress, by an April 12, 1900 act effective May 1, discontinued the tribunal and created a United States District Court to succeed it and take the records and pending cases. For those reasons the Court concluded the application could not be entertained and denied leave.
Real world impact
The practical result is immediate: the Supreme Court declined to review the tribunal, so the new federal district court will receive the tribunal’s records and take jurisdiction over pending matters. The municipal officers in Guayama must look to that district court rather than seek relief in the Supreme Court. The denial was procedural and not a decision on the underlying ouster claim.
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