People v. Gardiner

6 Park. Cr. 143
CourtNew York Supreme Court
DecidedNovember 15, 1865
StatusPublished

This text of 6 Park. Cr. 143 (People v. Gardiner) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Gardiner, 6 Park. Cr. 143 (N.Y. Super. Ct. 1865).

Opinion

By the Court, Mason, J.

This court has no jurisdiction to review the question here raised on this bill of exceptions. Bills of exceptions, by which questions of law made and decided on criminal trials may be brought up and reviewed in a higher court, were unknown to the common law; and although allowed by our statutes, yet the statute limits the right to exceptions taken on the trial of the main issue, and does not reach such questions as are raised by this plea on the preliminary question of jurisdiction. The words of the statute are: “ On the trial of any indictment, exceptions to any decisions of the court may be made by the defendant, in the same cases and manner as pro- . vided bylaw in civil cases.” (2 R. S., 736, § 21.) A trial of this plea to the jurisdiction, is not a trial of the indictment, but is preliminary thereto, and to ascertain and determine whether the court has jurisdiction' to • try the defendant upon the indictment. The case of Freeman v. The People (4 Denio R., 10) decides this question.

But assuming that the argument of the people’s demurrer to the defendant’s plea to the jurisdiction of the court to try this prisoner for the offense charged in the indictment, is the trial of the indictment (which is much easier assumed than maintained), then the question arises: Has the court of Oyer and Terminer jurisdiction to try this defendant for this alleged murder ? • Murder is .one of the [142]*142highest crimes known to the common law, and the court of Oyer and Terminer of this State had general jurisdiction of the offense long before the adoption of the Constitution of the United States; and their jurisdiction to try such offenses has never hitherto been questioned where the offense was committed within the jurisdiction of the State and against the laws of the State. This murder is alleged- to have been committed in the county of Chemung, in which the prisoner is charged to have murdered a citizen of the State, and the indictment is preferred against him by the grand jury of the county of Chemung, charging him with this offense, against the laws of the State.

The defendant’s plea to the jurisdiction of the court is predicated on the twentieth section of the act of Congress of March 3d, 1863 (U. S. Statutes at Large, p. 737, vol. 12), which declares “ that in time' of war, insurrection or rebellion, murder, assault and battery with intent to kill, manslaughter, mayhem, wounding by shooting with intent to commit murder, robbery, arson, burglary, rape, assault and battery with intent to commit rape, and larceny, shall be punishable by the sentence of a general court martial or military commission, when committed by persons who are in the military service of the United States, and subject to the articles of war; and the punishment for such offence shall never be less than those inflicted by the laws of the State, or territory, or district, in which they may have been committed.” The plea sets up that the defendant was a soldier in the military service during war, insurrection and rebellion, and subject to the articles of war at the time the said offense is alleged to have been committed; and that he is only amenable to military commission or general court martial, which have sole and exclusive jurisdiction of the offense.

The first question to. be considered is, whether this act of Congress is a constitutional and valid act. The thirteenth subdivision of- section eighth of the Constitution [143]*143declares that Congress shall have power “ to malee-rules for the government and regulation of the land and naval forces;" and the fifth article of the amendment of the Constitution declares that no person shall be held to answer for a capital or otherwise infamous crime unless on a presentment or indictment of a grand jury, “ except in cases ansing in the land and naval forces, or in the militia, when in actual service in time of war or public danger." There can be no doubt, I think, that in time of war or public dang&r Congress has the power to provide for the government of the land and naval forces of the United States, and to declare what shall be military offenses, when committed by those in the military service of the-government, and to provide for tlieir punishment by military commission or general court martial. This power seems to be clearly contained in sub-section thirteen of section eight, and in the fifth article of the amendments referred to; and the executive branch of the government have certainly decided in the case of Reuben Staal, convicted by military court martial in the State of Ohio, that this act of Congress is valid. On the advice of Judge Advocate Holt, I fully concur in the result of this opinion of Judge Holt, holding this act constitutional.

The next and more important question is, whether this act of Congress, conferring this jurisdiction upon the military courts martial, is exclusive, and divests the State courts of jurisdiction in similar cases. This depends upon the question whether this act of Congress supersedes and nullifies the State statutes and the common law, so far. as it applies to the crime of murder committed by soldiers in the military service of the United States. If it be conceded that Congress has exclusive jurisdiction or control over this subject, it does not follow that the jurisdiction of the State courts are excluded, unless by the act in question they have assumed to exclude the jurisdiction of the State courts by the clear language of the act itself. ■ There [144]*144is no reference to the State courts in the act, and nothing said in reference to them. The act simply says such offenses shall be punishable by general court martial or military commission, which means nothing more than they may be punishable by general court martial or military commission.

All that is meant by the act is to confer jurisdiction upon those military courts to try such offenses, and to declare them military offenses. It merely creates ttose cases enumerated in the act into military offenses, and provides for their punishment by military courts. It was never intended to abolish the crime of murder at common law, or as defined by State statutes. On the contrary, the act itself seems to contemplate the existence and continuance of the State laws, for the act of Congress itself provides that the punishment to be imposed by such military courts for such offenses shall not be less than those inflicted by the laws of the State, territory or district in which they have been committed; and as the act of Congress does not define the punishment, but refers to the State laws for the prescribed punishment, I think it is very clear that it was never intended by this act to supersede or nullify the State laws; and this should not be inferred or intended except upon the most clear and explicit language. It was held by the court of dernier resort in this State, in the case of The People v. Enoch (13 Wend. R., 159), that our statutes defining murder and homicide did not supersede or abolish the common law crime of murder, and that notwithstanding the change created by those statutes, an indictment at common law for murder would lie. The act of Congress not having superseded our State laws upon the subject of murder, this indictment is well found by alleging this murder to be against the peace “ of the people of the State of New York, their laws and dignity; ” and there can be no doubt, I think, as to the jurisdiction of the court of Oyer and Terminer to try the prisoner for this

[145]*145offense.

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6 Park. Cr. 143, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-gardiner-nysupct-1865.