United States v. Jackalow
| United States v. Jackalow | |
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| Argued March 18, 1862 Decided March 24, 1862 |
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| Full case name | United States v. Jackalow |
| Citations | 66 U.S. 484 (more)
17 L. Ed. 225, 1 Black 484
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| Prior history | Certificate of division from conviction in C.C.D.N.J. |
| Subsequent history | Nol pros motion granted |
| Holding | |
| Under the Venue and Vicinage clauses, although the description of a U.S. state boundary is a question of law for the judge, the ascertainment and application of that boundary is a question of fact for the jury | |
| Court membership | |
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| Case opinions | |
| Majority | Nelson, joined by unanimous |
| Laws applied | |
| U.S. Const. art. III, § 2, cl. 3; U.S. Const. amend. VI | |
United States v. Jackalow, 66 U.S. (1 Black) 484 (1862), is a U.S. Supreme Court case interpreting the Venue and Vicinage clauses of the United States Constitution. It was an "unusual criminal case", and one of the few constitutional criminal cases from the Taney Court. Jackalow, a mariner from the Ryukyu Islands, was suspected of the robbery and murder of the captain of the sloop Spray, Jonathan Leete, and Jonathan's brother Elijah, while the ship was at sea. He was convicted of robbery in the Long Island Sound, but as there was disagreement over the question of jurisdiction between the two judges who heard the post-trial motion – Judge Mahlon Dickerson and Supreme Court Justice Robert Cooper Grier – the case was referred to the Supreme Court by certificate of division.
The Supreme Court directed the circuit court for the District of New Jersey to grant Jackalow a new trial. The Court held that, while the trial court should determine the description of the boundaries of New York and Connecticut, the ascertainment of their actual boundaries, and the application of those boundaries to the crime in question, should have been a question of fact for the jury. Jackalow was not retried and was released.
The trial attracted significant media interest. According to The New York Times, "every part in and near the Court room was crowded during the trial". The case is viewed as historically significant, because even though it occurred during the American Civil War, the federal courts focused on proper legal procedure and jurisprudence in a case unrelated to the war.
Jonathan T. Leete had captained the schooner Reaper, owned by James Frisbie, and crewed by a man of East Asian origin, John Canoe, commonly known as Jackalow, short for John Low or John Lord. After Jonathan gave up command of the Reaper, he and Jackalow worked on Jonathan's father's farm on Sachem's Head in Guilford, Connecticut, where Jackalow was regarded as family. At some point, while in New York, Jackalow had stolen $100 from Jonathan and fled to New Haven. He was returned to New York by the police, but Jonathan refused to testify against him and rehired him. Jonathan and his brother Elijah J. Leete subsequently bought the 30-ton sloop Spray, funded in part by a mortgage their father took out on his farm. Jonathan (the captain), Elijah, and Jackalow sailed the Spray together for two or three years. By March 1860, Jackalow had sailed with Jonathan for four years.
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