Просмотр кода страницы Английская Википедия:Barrett v. United States

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{{Infobox SCOTUS case
  |Litigants=Barrett v. United States
  |ArgueDate=January 21 
  |ArgueYear=1898
  |DecideDate=February 21
  |DecideYear=1898
  |FullName=Barrett v. United States
  |USVol=169
  |USPage=218
  |ParallelCitations=18 S. Ct. 327; 42 [[L. Ed.]] 723
  |Prior=''United States v. Barrett et al.'', 65 [[Federal Reporter|F.]] 62 (C.C.D.S.C. 1894)
  |Subsequent=none
  |Holding=[[South Carolina]] had not been divided into separate federal judicial districts.
  |Majority=[[Melville Fuller|Fuller]]
  |JoinMajority=''unanimous''
  |Concurrence=
  |JoinConcurrence=
  |Concurrence2=
  |JoinConcurrence2=
  |Concurrence/Dissent=
  |JoinConcurrence/Dissent=
  |Dissent=
  |JoinDissent=
  |Dissent2=
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  |LawsApplied=[[United States Constitution|U.S. Const.]], [[Article Three of the United States Constitution|Art. III, § 2, cl. 3.]] and [[Sixth Amendment to the United States Constitution|Amend. VI.]]
}}
'''''Barrett v. United States''''', 169 U.S. 218 (1898), was a case in which the [[Supreme Court of the United States]] held that [[South Carolina]] had never effectively been subdivided into separate [[United States district court|judicial districts]]. Therefore, it was held, a criminal defendant allegedly tried in one district for a crime committed in the other had in fact been permissibly been tried in a separate division of a single district.

== Facts of the case ==
The [[defendant]], Charles P. Barrett, was one of a group of men in [[Spartanburg, South Carolina]], alleged to have been involved in a [[conspiracy (crime)|conspiracy]] to defraud companies selling items by [[mail order]].<ref name=ccdsc>''United States v. Barrett et al.'', 
65 F. 62 (C.C.D.S.C. 1894).</ref> Barrett, apparently an attorney,<ref name=ccdsc/> arranged to have [[post office]]s established in rural areas with the name of each post office being the name of another defendant (e.g. Owens, McElrath, Wyatt). Companies sending mail to those individuals would thereby be led to think that the individuals were proprietors of the respective post offices.<ref name=ccdsc/> Barrett also created a [[letterhead]] on which to send orders for goods, in order to further induce the trust of the companies from which orders were placed, and his co-conspirators ordered goods including [[encyclopedia]]s, a [[piano]], an [[organ (music)|organ]], a [[desk]], and a [[safe]], none of which were ever paid for.<ref name=ccdsc/> The fraud was far reaching, as the trial court reported that parties coming to testify that they had been defrauded:

<blockquote>...came from [[New York City|New York]] and [[Chicago]], from [[New Jersey]] and [[Pennsylvania]], from [[Boston]], [[Baltimore]], and [[Atlanta]], from [[Washington, D.C.|Washington]], [[Richmond, Virginia|Richmond]], and [[Savannah, Georgia|Savannah]], from [[Charlotte, North Carolina|Charlotte]] and [[Augusta, Georgia|Augusta]]...<ref name=ccdsc/></blockquote>

Barrett and his co-conspirators were charged with conspiracy to defraud, and the trial was held in the [[United States circuit court]] in [[Columbia, South Carolina]], before judge [[William H. Brawley]]. Several of Barrett's co-conspirators pleaded guilty, and Barrett was convicted.

== Issue of the case ==
[[File:South Carolina - Barrett map.JPG|thumb|right|250px|Barrett was tried in Columbia, asserted to be in the Eastern District of South Carolina (in blue), for crimes committed in Spartanburg, asserted to be in the Western District of South Carolina (in red).]]
Barrett appealed, asserting that the trial was unconstitutional.<ref>''Barrett v. United States'', 169 U.S. at 220-21.</ref> The [[Vicinage Clause]] of the [[Sixth Amendment to the United States Constitution|Sixth Amendment]] states that "in all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law".

The [[United States District Court for the District of South Carolina]] was one of the original 13 courts established by the [[Judiciary Act of 1789]], 1 Stat. 73, on September 24, 1789.<ref name=fjcsc>[http://www.fjc.gov/history/home.nsf/page/usdc_sc_leg U.S. District Courts of South Carolina, Legislative history] {{webarchive |url=https://web.archive.org/web/20090119214004/http://www.fjc.gov/history/home.nsf/page/usdc_sc_leg |date=January 19, 2009 }}, ''[[Federal Judicial Center]]''.</ref> [[United States Congress|Congress]] had, in various pieces of legislation, subdivided South Carolina into Eastern and Western jurisdictions, and set forth the times when the circuit court of each jurisdiction would sit.<ref>''Barrett v. United States'', 169 U.S. at 221-25.</ref> The most recent rewording of these, adopted June 22, 1874,<ref>''Barrett v. United States'', 169 U.S. at 225.</ref> included a provision that:

<blockquote>The State of South Carolina is divided into two districts, which shall be called the eastern and western districts of the district of South Carolina. The western district includes the counties of [[Lancaster County, South Carolina|Lancaster]], [[Chester County, South Carolina|Chester]], [[York County, South Carolina|York]], [[Union County, South Carolina|Union]], [[Spartanburg County, South Carolina|Spartanburg]], [[Greenville County, South Carolina|Greenville]], [[Pendleton District, South Carolina|Pendleton]], [[Abbeville County, South Carolina|Abbeville]], [[Edgefield County, South Carolina|Edgefield]], [[Newberry County, South Carolina|Newberry]], [[Laurens County, South Carolina|Laurens]] and [[Fairfield County, South Carolina|Fairfield]], as they existed February 21, 1823. The eastern district includes the residue of said State.</blockquote>

The same act, however, provided that there would be a single [[United States federal judge|district court judge]], a single [[clerk of the court]],<ref>''Barrett v. United States'', 169 U.S. at 229-30.</ref> a single [[United States Attorney]], and a single [[United States Marshals Service|United States Marshal]]<ref>''Barrett v. United States'', 169 U.S. at 226-27.</ref> appointed for the entire state of South Carolina. Barrett's claim was that the state constituted two districts and that because the crime was alleged to have been committed in Spartanburg, in the western district, his trial in Columbia had not been held before a [[jury]] of the "district wherein the crime shall have been committed".

== Opinion of the Court ==
The Supreme Court, in a unanimous opinion written by [[Chief Justice of the United States|Chief Justice]] [[Melville Fuller]], held that Congress had never intended to divide South Carolina into separate judicial districts. The language adopted in 1874 had not been enacted by Congress but was merely a rewording of a previous statute which had been enacted in 1823. The 1823 statute was referenced in the margin of the 1874 act, and had stated: "The district of South Carolina is divided into two divisions, which will be called the eastern and western divisions of the district of South Carolina". The Supreme Court found that "Congress... seems to have construed the act of 1823, not as dividing the State into two judicial districts, as indicated in the title of the act, but into two districts in the sense of geographical divisions, which is in harmony with the language used in the body of the act".

Finding that the state of South Carolina constituted a single judicial district, the Court found it unnecessary to further examine the jurisdiction of the circuit court.<ref name=US230>''Barrett v. United States'', 169 U.S. at 230.</ref> Rather, it determined that Barrett was tried and convicted in the district in which the crime had been committed and that the jury had likewise been empaneled from that district.<ref name=US230/>

==Later developments==
The case itself, standing for a particularly narrow proposition, was only cited in a handful of later decisions by other courts, and only once by the United States Supreme Court for the proposition decided in the case. That decision, ''[[Matheson v. United States]]'',<ref>{{ussc|name=Matheson v. United States|volume=227|page=540|pin=|year=1913}}.</ref> similarly held that no constitutional error occurred when a criminal defendant accused of a crime in one part of [[Alaska]] was prosecuted in another, the territorial court having been arranged in divisions.

Congress made a more explicit effort to subdivide the District of South Carolina on March 3, 1911, by 36 Stat. 1087, 1123.<ref name=fjcsc/> South Carolina was again subdivided into Eastern and the Western Districts, with one judgeship authorized to serve both districts, effective January 1, 1912.<ref name=fjcsc/> Congress finally authorized an additional judgeship for the Western District, and assigned the sitting judge exclusively to the Eastern District, on March 3, 1915, by 38 Stat. 961.<ref name=fjcsc/> However, on October 7, 1965, by 79 Stat. 951, South Carolina was reorganized as a single judicial district with four judgeships authorized for the district court.<ref name=fjcsc/> It has since remained a single District.

==References==
{{reflist}}

==External links==
* {{wikisource-inline}}
* {{caselaw source
 | case = ''Barrett v. United States'', {{ussc|169|218|1898|el=no}}
 | googlescholar = https://scholar.google.com/scholar_case?case=14081795311929423204
 | justia =https://supreme.justia.com/cases/federal/us/169/218/
 | loc =http://cdn.loc.gov/service/ll/usrep/usrep169/usrep169218/usrep169218.pdf
 }}

{{USArticleIII}}
{{USDistCourts}}

[[Category:1898 in South Carolina]]
[[Category:1898 in United States case law]]
[[Category:Legal history of South Carolina]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court cases of the Fuller Court]]
[[Category:United States Constitution Article Three case law]]
[[Category:United States Constitution Article Three venue case law]]
[[Category:United States Sixth Amendment case law]]
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