Smith v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Smith v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Smith v. United States.
In Smith v. United States, the Supreme Court addressed whether retrial is permissible after a trial in an improper venue. The Court concluded that retrial is allowed, as the Constitution does not bar it under such circumstances. The decision clarified that violations of the Venue and Vicinage Clauses do not preclude retrial.
Holding
The single most important “bottom line” of what the Court decided in Smith v. United States.
The Court held that the Constitution permits the retrial of a defendant following a trial in an improper venue conducted before a jury drawn from the wrong district.
Constitutional Concepts
These are the Constitution-related themes that appear in Smith v. United States. Click a concept to see other cases that involve the same idea.
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Why Double Jeopardy is relevant to Smith v. United States
The Court addressed whether retrial is barred by the Double Jeopardy Clause after a trial in an improper venue.
Syllabus excerpt (verbatim)The Court rejects Smith's argument that the Double Jeopardy Clause is implicated by retrial in a proper venue.
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Why Right to Jury Trial is relevant to Smith v. United States
The case involves the Vicinage Clause, which is part of the Sixth Amendment's jury trial rights.
Syllabus excerpt (verbatim)The Vicinage Clause—which guarantees 'the right to . . . an impartial jury of the State and district wherein the crime shall have been committed,' Amdt. 6.
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Why Procedural Due Process is relevant to Smith v. United States
The case discusses the procedural aspect of venue and vicinage rights, which are part of ensuring fair trial procedures.
Syllabus excerpt (verbatim)The District Court concluded that factual disputes related to venue should be resolved by the jury.
Key Quotes
Short excerpts from the syllabus in Smith v. United States that support the summary and concepts above.
The Constitution permits the retrial of a defendant following a trial in an improper venue.
The Venue Clause mandates that the 'Trial of all Crimes . . . shall be held in the State where the . . . Crimes shall have been committed.'
Reversal of a conviction based on a violation of the Venue or Vicinage Clauses does not resolve 'the bottom-line question of `criminal culpability.'
