United States v. Anthony T. Santos, Vincente M. Santos, Anthony Calvo Cepeda, Juan Q. Salas, Tito Naputi, and Pedro Q. Salas, Movants-Appellants

Appellants were convicted of depriving certain inhabitants of the Territory of Guam of their civil rights. The judgment was affirmed on appeal to this court. United States v. Santos, 588 F.2d 1300 (9th Cir. 1979). Appellants then brought this action under 28 U.S.C. § 2255 , seeking to have their sentences vacated on the ground that the District Court of Guam was without jurisdiction to entertain the criminal complaints against them. The question presented is whether jurisdiction to hear criminal cases involving violations of federal law has by statute been conferred on the District Court of Guam.

As originally enacted in 1950, 48 U.S.C. § 1424 (a) provided:

Courts so defined have exclusive jurisdiction over all criminal offenses against the laws of the United States. Thus, as originally enacted § 1424(a) conferred criminal jurisdiction on the District Court of Guam.

In 1958, the section was amended to read in part:

Legislative history indicates that the emphasized portion was added for the reason that it was felt that the omission of that portion from the statute as originally enacted inadvertently limited the civil jurisdiction of the court, contrary to legislative intent.…