United States v. Press Publishing Co.

Background

A person was indicted in federal court for criminal libel after a newspaper containing a libelous article was printed in New York and a copy circulated on a United States reservation. The indictment rested on the 1898 law that makes certain state criminal laws applicable on federal reservations when no federal law covers the offense. The federal trial court quashed the indictment, and the case reached this Court for review.

Reasoning

The Court examined the 1898 statute and its predecessors and concluded Congress intended to adopt the state criminal law as written when no federal law applies. That means state rules about where and how a crime may be prosecuted — including New York’s limits on venue and on multiple prosecutions for the same libel — travel with the state law. Because New York law provided a single, state-centered way to punish a newspaper libel, the circulation of a paper on the reservation was not a separate federal offense authorizing a new federal prosecution.

Real world impact

The Court affirmed the lower court’s quashing of the indictment because applying the federal statute to allow a separate federal prosecution would conflict with New York’s law and defeat that law’s purpose. The decision leaves open cases where a crime is wholly committed on a reservation and disconnected from acts inside the State; the Court did not decide those situations.