United States v. Hudson and Goodwin
"United States v. Hudson and Goodwin" is a significant legal case that emerged from the political tensions between the Democratic Republicans and the Federalists in early 19th-century America. The case centers on Barzillai Hudson and George Goodwin, who were indicted for seditious libel following the publication of a report that connected President Thomas Jefferson with Napoleon Bonaparte. This indictment sparked a broader debate regarding the existence of federal common law for criminal offenses. The Democratic Republicans argued that federal courts lacked the authority to enforce common-law crimes, holding that governmental powers should be strictly limited to those outlined in the Constitution. The case ultimately reached a federal court where a majority composed of Democratic Republican appointees dismissed the indictments, thereby resolving the legal dispute over common law at the federal level. This ruling has since been recognized as a significant precedent in the ongoing discussion of federal authority and the interpretation of common law within the United States legal system. "United States v. Hudson and Goodwin" remains an important case for understanding the evolution of American legal principles and the balance of power between federal and state jurisdictions.
United States v. Hudson and Goodwin
Date: February 13 or March 14, 1812
Citation: 11 U.S. 32
Issue: Federal common law
Significance: The Supreme Court ended a long-standing dispute by disavowing the existence of a federal common law for crimes.
For ten years, the Democratic Republicans and the Federalists had disagreed over whether there was a federal common law for criminal offenses. Barzillai Hudson and George Goodwin, who published a report linking Thomas Jefferson and Napoleon Bonaparte, were indicted for common-law seditious libel in federal court. The Democratic Republicans believed that the branches of the federal government held only the powers specifically granted by the Constitution, and therefore, federal courts did not have the power to enforce common-law crimes. The Court, on which Democratic Republican appointees were in the majority, dismissed the indictments, resolving the dispute. The case remains a valid holding.
