Double Jeopardy Case Study

In 2008, Luis M. Sanchez Valle was charged by the federal courts with trafficking weapons and ammunition in interstate commerce, and then was charged for the same offense by the Puerto Rican Courts. After Valle was convicted in federal, he filed a motion to dismiss the Puerto Rican Court’s ruling, saying it violated his 5th Amendment right to protection from Double Jeopardy. The prosecution argued that the United States and Puerto Rico derive their authority from different sources, and therefore can punish the same offenses without breaking his constitutional protections against double jeopardy. The case went through the trial court and then the court of appeals, which both agreed with Valle. It is now moving on to the Supreme Court.
In Benton v. Maryland, John Dalmer Benton was acquitted of larceny and convicted of burglary in Maryland, and after undergoing a new trial, he was

again acquitted with larceny. The Supreme Court ruled in favor of Benton, saying that the Fifth Amendment's Double Jeopardy Clause is applicable to both state and federal proceedings. Prior to this ruling, an individual accused of violating state law could rely only on that particular state's protection against double jeopardy, which The Supreme Court said was impermissible. In Rutledge v. United States, Tommy Ruff Edge organized and supervised a cocaine distribution enterprise until his arrest by federal agents. After trial, a jury found Rutledge guilty and the District Court sentenced Rutledge to life in prison without parole, and was charged $300 by the CCE; Rutledge argued the two punishments violated his right to protection from double jeopardy. The Supreme Court ruled that narcotics conspiracy constitutes a lesser included offense of CCE and that the court did not intend to authorize more than one punishment, and therefore, multiple convictions and sentences for CCE and conspiracy violate the Double Jeopardy Clause. In Yeager v. United States, a jury in a federal district court acquitted F. Scott Yeager of conspiracy, wire fraud, and security fraud, but soon after, the district court declared a mistrial on the counts the jury hung on. Thereafter, Yeager was again charged on a portion of the mistried counts, but he believed as the jury had already decided upon information, that it could not be brought up again. The Supreme Court ruled in favor of Yeager, saying "if the possession of insider information was a critical issue of ultimate fact in all of the charges [against him], a jury that decided that issue in his favor protects him from prosecution for any charges for which that [fact] is an essential element." In Palko v. Connecticut, Frank Palko was acquitted with first-degree murder, but convicted of second-degree murder. The state of Connecticut then found Palko guilty of first-degree murder and sentenced him to death. Palko said this violated his 5th Amendment rights, and his attorneys said that the state had no right to violate it based on the 14th Amendment. The Supreme Court ruled in favor of Connecticut, saying “that the Fourteenth Amendment did not incorporate the Fifth Amendment's protection against double jeopardy.”
The case Puerto Rico v.

Valle deals with an individual's right to protection from double jeopardy, named in the 5th Amendment, but is different in many ways from precedents before it. This is because would-be precedents have overwhelmingly only dealt with how states laws against double jeopardy clash with those with the federal courts provide. This case deals with both the United States. and Puerto Rico charging an individual, in this case Sanchez Valle, with the same offense. The Puerto Rican constitution is modeled after the U.S.s own, but a lot of grey area remains. The majority of the U.S.’s precedent cases have ruled in favor of the individual at stake, as the majority of justices have agreed that all individuals have the right to fair trial. As an individual placed in double jeopardy would lose their fundamental rights provided by the constitution, even if it is not considered to be as important as the right to free speech, or even if the charges are made by separate sovereign entities, should not be tolerated. All charges against Luis M. Sanchez Valle made in federal are

dropped.
It is so ordered.