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 a defendant can be retried after a conviction in an improper venue. The Court found that retrial is permissible following such a trial, as the Constitution does not bar reprosecution in a proper venue. 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 addresses whether retrial in a proper venue implicates the Double Jeopardy Clause.
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 right to a jury trial in the correct district, as guaranteed by the Vicinage Clause.
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.
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 conducted before a jury drawn from the wrong district.
The Venue Clause mandates that the 'Trial of all Crimes . . . shall be held in the State where the . . . Crimes shall have been committed.'
The Vicinage Clause—which guarantees 'the right to . . . an impartial jury of the State and district wherein the crime shall have been committed.'