Amado v. United States

Background

A man named Amado was indicted in the federal district court in Puerto Rico for receiving, concealing, and facilitating sale and transport of Holland gin, vermouth, brandy, and Danish beer that had been imported without paying customs duties. He was tried, convicted by a jury, and sentenced to one year and one day in prison and a $500 fine. After his motion to arrest judgment and a request for a new trial were denied, he sought review by this Court through a writ of error.

Reasoning

The Court considered whether it could review the criminal judgment under the 1900 law that organized the Porto Rico courts. That law allows appeals to this Court only in cases where the Constitution, a treaty, or an act of Congress is brought in question and a right under them is denied. The Court explained civil cases can be treated broadly, but criminal cases require a clear assertion of a federal right. Amado’s claim that the indictment did not charge an offense was too general and did not assert a specific federal right, so the Court had no jurisdiction to review.

Real world impact

Because the Court dismissed the writ of error for lack of jurisdiction, Amado’s conviction, sentence, and fine remain in force. The decision means criminal defendants in Puerto Rico cannot obtain this Court’s review unless they clearly claim and are denied a right under the Constitution, a treaty, or an act of Congress. The ruling also confirms that criminal appeals from the Porto Rico district court do not go to a federal Circuit Court of Appeals.