United States v. Mayer

Background

This dispute involved the United States and a federal district judge after the judge entertained an application to set aside a final criminal judgment after the term when that judgment was entered. The Circuit Court of Appeals certified legal questions about whether the District Court could reopen its final judgment after the term, whether the United States attorney’s consent mattered, and whether the appellate court could issue a writ to stop the lower court.

Reasoning

The Court addressed whether, absent a specific statute, a trial court may change or vacate a final judgment once the term when the judgment was entered has ended. Relying on the long-standing rule that courts generally cannot alter final judgments after the term except for narrow clerical or fundamental factual errors, the Court held the District Court lacked power to entertain the new-trial application after the term. The Court also ruled that the prosecutor’s consent could not create jurisdiction the court did not have. Finally, the Court recognized that the Circuit Court of Appeals, whose appellate jurisdiction had already attached on the defendant’s writ of error, could properly issue a writ of prohibition to prevent unauthorized action by the lower court. The Court answered one certified question affirmatively, answered two negatively, and declined to answer another question as not presented.

Real world impact

The decision preserves the finality of lower-court criminal judgments after a term ends, prevents prosecutors from supplying missing jurisdiction by consent, and allows appellate courts to block improper reopening of cases to protect the record and the appeals process.