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Balzac v. Porto Rico
United States Supreme Court
258 U.S. 298 (1922)
Jesus Balzac (defendant) was the editor of a Puerto Rican newspaper. Balzac was charged by the Puerto Rican government (plaintiff) for criminal libel for publishing allegedly libelous articles. All of the charges brought by the government were misdemeanors. Balzac demanded a jury trial under the Sixth Amendment to the United States Constitution and further claimed that the speech charged as libel was protected by the First Amendment. Because the Code of Criminal Procedure of Puerto Rico granted jury trials only for felonies, Balzac’s claims were overruled. Balzac’s case was tried before a judge, and he was convicted and sentenced to serve prison time. On appeal to the Supreme Court of Puerto Rico, Balzac argued that when the United States Congress passed the Jones Act, it implied an intent to adopt Puerto Rico into the Union. The Jones Act provided a Bill of Rights to the citizens of Puerto Rico that largely mirrored the United States Bill of Rights, but without the right to trial by jury. The Supreme Court of Puerto Rico ultimately affirmed the lower court’s judgment. Balzac appealed.
Rule of Law
Holding and Reasoning (Taft, C.J.)
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