Commonwealth v. Kuchel

1 Vaux 174
CourtRecorder of Philadelphia
DecidedJuly 1, 1846
StatusPublished

This text of 1 Vaux 174 (Commonwealth v. Kuchel) is published on Counsel Stack Legal Research, covering Recorder of Philadelphia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Kuchel, 1 Vaux 174 (philarec 1846).

Opinion

And now after argument of counsel, to wit, on the 5th of November, 1845, the Recorder gave the following decision:

On the hearing of the above case, H. M. Phillips, esq., counsel for the prisoner, moved his discharge, 1st, because the offence was not a crime within the meaning of the constitution; and 2d, because it is shown that he left New York some months after the alleged offence, if any was committed, was consummated. J. S. Brewster, esq., for the commonwealth, opposed the [175]*175motion on the ground that the offence was recognised under the general designation of crime, and that there was no period determined by any law at which, if one left the jurisdiction, having violated the then existing law, such leaving was to be construed as not fleeing from justice.

As the decision of the question raised by the motion of the prisoner’s counsel, involves much importance both as to the law and the practice in cases of persons charged with being fugitives from justice, I have thought it proper to put my views in writing, in order that some general idea may be had of the nature and objects of the constitutional provisions in such cases. Another reason has induced me to this conclusion, which is found in the fact, that much speculation is indulged in, as to the intended operation of these constitutional provisions.

By the 2d sect, of the 10th art. of the constitution of the United States, and the 2d subdivision of the section, it is declared that “a person charged in any state, with treason, felony, or other crime, who shall flee from justice, and be found in another state, shall on demand of the executive authority of the same state from which he fled, be delivered up, to be removed to the state having jurisdiction of the crime.”

The congress of the United States on the 12th day of February, 1793, passed the following act, pointing out the mode by which the provision of the constitution should be enforced.

Sect. 1. “Be it enacted, &c., That whenever the executive authority of any state in the Union, or of either of the territories north-west or south of the river [176]*176Ohio, shall demaud any person as a fugitive from justice of the executive authority of any such state or territory to which such person shall have fled, and shall moreover produce the copy of an indictment found, or an affidavit made before a magistrate of any state or territory as aforesaid, charging the person so demanded with having committed treason, felony, or other crime, certified as authentic by the governor or chief magistrate of the state or territory from whence the person so charged fled, it shall be the duty of the executive authority of the state or territory to which such person shall have fled, to cause him or her to be arrested and secured, and notice of the arrest to be given to the executive authority making such demand, or to the agent of such authority appointed to receive the fugitive, and cause the fugitive to be delivered to such agent when he shall appear: but if no such agent shall appear within six months from the time of the arrest, the prisoner may be discharged. And all costs or expenses incurred in the apprehension, securing and transmitting such fugitive to the state or territory making such demand, shall be paid by such state or territory.”

By the terms of the constitution, each state was authorized to make its own laws; or in other words, the sovereignty of the individual members of the confederation over their own citizens and soils, was not interfered with by the constitution, so far as related to those subjects, which such individual states had not ceded to the jurisdiction and authority of the confederation.

Among the most conspicuous of the sovereign rights [177]*177of the states, was that of making their own laws. Each, state therefore, established among others, its own penal laws. By these penal laws, enacted by the different states as the wisdom of the state legislatures conceived the public interests required, a certain class of offences were made felonies, and others misdemeanors. In some states those offences which were constituted felonies, were in others only misdemeanors, and indeed in this connexion, it is not a little curious to contrast the several penal codes, as showing the severity or clemency of the various penal laws of the states.

The framers of the constitution of the United States —being aware of the right of each state to make its own penal laws, and knowing the impossibility of including in the general terms of a constitutional provision, all the offences which it would be the policy of the several states to punish with more or less severity, as inferior in grade to felonies — used in the 2d section as above quoted, the terms, treason, felony and other crime, as including all those offences which the safety of persons and property, required to be properly punished.

The object of this constitutional provision as to fugitives from justice, was to enable one state to demand from the authority of a separate and independent state, a citizen, who having violated the laws of his own, had voluntarily banished himself into another member of the confederation; without such provision, from the nature of the confederacy, he could not have been made amenable to punishment in the state whose laws he had violated, for there would have been no mode for effecting his arrest and delivery for trial. It is to be [178]*178observed, that the act of congress only provides a form of arrest and delivery; it does not forbid the arrest of the fugitive by the state authorities, before the “demand” is made by the executive of the state, from which such fugitive has fled.

It was as plain at the time of the formation of the constitution, as it is now, what offences were included under the terms treason and felony. It was as impossible- then to have decided for what other offences fugitives should be demanded and delivered, as it would be now to determine, what other acts of individuals the several states may think fit to constitute as penal offences, and punishable as such.

The improvement of the social condition, while it may serve to leave as a dead letter on the penal code, certain statutes against acts which have ceased to be committed, nevertheless may engender in Society the disposition to commit, and the committal of acts which the public interests may require should be prevented, by the punishment of those, who thus jeopardize such public interest.

Experience shows this to be the case. We have now, statutes declaring as misdemeanors, and punishing with imprisonment, offences, which at the time of the formation of the constitution of the United States, and the enacting of the provision in regard to fugitives from justice, were not and could not under the then condition of society, have been as such included within its meaning.

It cannot be contended however that for such of-fences a fugitive, having committed them, could not be demanded under the constitution. It was to guard [179]*179against such contingency, one too likely to arise, that the words “other crime” were added to the article of the constitution relative to fugitives from justice.

The crime of treason, and the various other crimes which were then or may have since been made felonies, were included by the constitution.

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9 Wend. 212 (New York Supreme Court, 1832)

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Bluebook (online)
1 Vaux 174, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-kuchel-philarec-1846.