Crowley v. United States
Headline: Grand jury rules in Porto Rico reversed: Court invalidates indictment because three jurors were disqualified under a new local law, allowing defendants to challenge such indictments.
Holding: The Court held that the presence of three grand jurors who were disqualified under Porto Rico’s local statute vitiated the indictment, and it reversed the judgment and remanded for further proceedings.
- Allows defendants to void indictments if grand jurors were disqualified under Puerto Rico law.
- Requires federal courts in Porto Rico to follow local juror qualification laws.
- Permits timely plea in abatement to challenge grand jury composition after indictment is returned.
Summary
Background
A person was indicted in the District Court of the United States for Porto Rico on crimes against the United States. The Government used a grand jury to return the indictment. Porto Rico's legislature passed a law effective April 1, 1901, setting juror qualifications — requiring male citizenship, age limits, one-year island residency, ninety days' district residency, and a property assessment of at least $200. The record shows several grand jurors were summoned after that date; three named jurors were later admitted not to meet the new residency or property requirements.
Reasoning
The Court first held it had authority to decide because the case raised a question under an act of Congress. Reading the Foraker Act and federal statutes together, the Court said federal prosecutions in Porto Rico should follow the same practice about juror qualifications as federal courts do in states. The Court found the accused had timely and properly raised the objection by a plea in abatement after the indictment and before arraignment, since he was not present when the grand jury was empaneled. Because the disqualifications were substantive, not mere formal defects, the presence of disqualified jurors vitiated the indictment. The Court reversed the judgment and sent the case back with instructions to overrule the demurrer to the plea.
Real world impact
The ruling requires federal courts in Porto Rico to respect local juror laws when organizing grand juries. Defendants may challenge indictments if disqualified jurors sat, and such objections can be raised promptly after indictment. The decision was corrective, not necessarily final on other legal issues in the record.
Dissents or concurrances
Justice McKenna agreed with the result. Justice White dissented; his separate views are not detailed in the opinion.
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