Grafton v. United States
Headline: Court blocks civil retrial of a U.S. soldier in the Philippines after military acquittal, ruling double jeopardy bars a second prosecution by the same U.S. authority in the territory.
Holding: The Court held that a soldier acquitted by a U.S. military court for killings in the Philippines cannot be retried by a civil Philippine court under U.S. authority because the double jeopardy protection bars a second prosecution for the same offense.
- Prevents civil retrial after a valid military acquittal in U.S.-run territories.
- Requires dismissal and release when civil conviction follows a competent military acquittal.
Summary
Background
Homer E. Grafton, a private in the U.S. Army, was tried by a general court-martial in 1904 for shooting two Filipino men and was acquitted. Later the local prosecutor in the Province of Iloilo filed a criminal information in the Court of First Instance charging him with killing one of those men. That civil court tried Grafton without a jury, found him guilty of homicide, and sentenced him to imprisonment. The case was appealed to the Supreme Court of the Philippines and then brought to this Court for review.
Reasoning
The Court addressed whether a military acquittal by a court-martial that had jurisdiction prevents a later civil trial by a court in the Philippines that acted under United States authority. The opinion explains that the 1902 act extending the protection against double jeopardy to the Islands and longstanding decisions give finality to convictions or acquittals by tribunals with proper jurisdiction. Because the court-martial had authority under the Articles of War to try noncapital crimes by soldiers, its acquittal meant Grafton had been put in jeopardy and could not be tried again for the same acts by another tribunal of the same government.
Real world impact
The Court reversed the civil conviction, ordered dismissal of the information, and directed the Supreme Court of the Philippines to discharge Grafton. The ruling means that when courts created by the United States try a soldier and have jurisdiction, civil tribunals deriving their authority from the same government cannot retry the same offense.
Dissents or concurrances
The Supreme Court of the Philippines had been divided: three of seven judges thought Grafton should have been acquitted, a fact the opinion noted in explaining the controversy.
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