United States v. Hudson

United States v. Hudson and Goodwin, 11 U.S. (7 Cranch) 32 (1812), was a case in which the United States Supreme Court held that Congress must first enact a constitutional law criminalizing an activity, attach a penalty, and give the federal courts jurisdiction over the offense in order for the court to render a conviction.

Barzillai Hudson and George Goodwin, the defendants in the case, were charged with a libel on the President and Congress, and of having accused them of secretly voting to give Napoleon Bonaparte $2 million to make a treaty with Spain.

The circuit court was divided on whether it could exercise common law jurisdiction over such cases.

Furthermore, only the jurisdiction of the Supreme Court was explicitly defined in Article III of the U.S. Constitution.

The case effectively closed the door on the lower federal courts' powers to convict defendants for common law crimes and mandated Congress to define criminal jurisdiction specifically, through legislation.