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Media Alerts - United States v. Hollingsworth - Fifth Circuit
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April 15, 2015
  United States v. Hollingsworth - Fifth Circuit
Headline: Fifth Circuit Rules that Defendants Tried for Petty Offenses Committed on Federal Enclaves Are Not Entitled to a Trial Before an Article III Judge.

Area of Law: Article III of the United States Constitution.

Issue Presented: Whether a defendant charged with a petty offense on a federal enclave acquired by Congress pursuant to Article I, Section 8, Clause 17 of the United States Constitution is entitled to a trial before an Article III judge.

Brief Summary: A federal magistrate judge tried David Hollingsworth for a petty offense committed on a federal enclave, namely a military base located in Louisiana. The magistrate judge conducted a bench trial, entered a verdict of guilty, and sentenced Hollingsworth to six months in federal prison. Hollingsworth objected to trial before the federal magistrate judge, but the magistrate judge held that she had jurisdiction to try Hollingsworth without his consent. Hollingsworth appealed to the U.S. District Court for the Eastern District of Louisiana, arguing that he had the right to a jury trial. The district court affirmed the judgment and sentence entered by the magistrate judge. Hollingsworth then appealed to the U.S. Court of Appeals for the Fifth Circuit, arguing that he had a constitutional right to trial before an Article III judge. The Fifth Circuit affirmed, holding that there is no right to trial before an Article III judge for a petty offense committed on a federal enclave. The court reasoned that Article I, Section 8, Clause 17 of the United States Constitution provides Congress with extensive regulatory authority over land acquired for federal use and that this authority permits Congress to endow magistrate judges with the power to try, at a minimum, petty offenses committed there.

Judge Higginbotham's concurrence noted the importance of the fact that a petty offense was at issue.

Judge Higginson's dissent focused on the incremental reassignment of federal judicial power away from Article III judges.

For the full opinion, please see:
http://www.ca5.uscourts.gov/op...ub/13/13-31265-CR0.pdf.

Panel: Circuit Judges Higginbotham, Clement, and Higginson.

Argument Date: 12/2/2014

Date of Issued Opinion: 4/14/2015

Docket Number: No. 13-31265

Decided: Affirmed

Case Alert Author: Kirsty Davis

Counsel: John Rivera, U.S. Attorney's Office, for Plaintiff-Appellee United States; Jordan Mark Siverd, Federal Public Defender's Office for the Eastern District of Louisiana, for Defendant-Appellant Hollingsworth.

Author of Opinion: Judge Clement (Judge Higginbotham concurring and Judge Higginson dissenting)

Case Alert Circuit Supervisor: Aaron-Andrew P. Bruhl

    Posted By: Aaron Bruhl @ 04/15/2015 09:31 PM     5th Circuit  

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