United States v. Hudson and Goodwin
United States Supreme Court
11 U.S. (7 Cranch) 32 (1812)
Hudson and Goodwin (defendants) published an accusation in a Connecticut newspaper that the President and Congress had secretly arranged to pay Napoleon Bonaparte two million dollars for permission to negotiate a treaty with Spain. The United States (plaintiff) indicted them for libel, a common law crime, in the federal circuit court for Connecticut. The defendants argued federal courts had no jurisdiction over common law crimes, and the circuit court certified the jurisdictional question to the Supreme Court.
Whether a federal court may exercise jurisdiction over a common law crime, such as libel, in the absence of a federal statute defining the crime, prescribing its punishment, and conferring jurisdiction over it.