## Facts

- Three U.S. Army soldiers, including Richard P. Adams, were convicted in federal district court for raping a civilian woman at Camp Claiborne, Louisiana.
- The prosecution relied on the federal rape statute applicable in the “special maritime and territorial jurisdiction” of the United States.
- Camp Claiborne was a federal military camp located on land to which the United States held title at the time of the offense.
- The Act of October 9, 1940 (40 U.S.C. § 255) required the United States to accept “exclusive or partial jurisdiction” over later-acquired lands within a state by filing notice with the state governor or taking similar official action.
- The United States had not filed any notice or otherwise formally accepted jurisdiction over the Camp Claiborne land under the 1940 Act.
- On appeal, the court of appeals certified questions to the Supreme Court regarding whether federal criminal jurisdiction existed absent formal acceptance and whether the district court had jurisdiction to try and sentence the soldiers.

## Issues

1. Whether, for lands within a state acquired by the United States after the 1940 Act, federal criminal jurisdiction exists absent formal acceptance of jurisdiction under 40 U.S.C. § 255.
2. Whether “partial jurisdiction” in 40 U.S.C. § 255 includes concurrent federal-state jurisdiction, such that concurrent jurisdiction also requires formal acceptance.
3. Whether the federal district court had jurisdiction to try and sentence the defendants for a rape allegedly committed at Camp Claiborne.

## Decision

- The Supreme Court answered the certified questions to the effect that the federal district court lacked jurisdiction.
- Because the United States had not accepted jurisdiction in the manner prescribed by 40 U.S.C. § 255, it possessed neither exclusive nor partial (including concurrent) jurisdiction over Camp Claiborne.
- The convictions could not stand because the federal statutes invoked depended on the offense occurring within federal territorial jurisdiction, which had not been established.

## Legal Principles

- For lands within a state acquired by the United States after enactment of 40 U.S.C. § 255, federal jurisdiction (exclusive or partial) does not attach unless the United States formally accepts it through the statute’s specified procedures.
- The statute’s “conclusive presumption” clause requires courts to presume no federal jurisdiction has been accepted unless and until the prescribed acceptance occurs; ownership and federal use of the land are insufficient.
- “Partial jurisdiction” under 40 U.S.C. § 255 includes concurrent jurisdiction; therefore, even shared federal-state criminal authority requires formal acceptance.
- States retain criminal jurisdiction over lands within their borders unless displaced by federal jurisdiction accepted as Congress has directed.

## Conclusion

The Supreme Court held that, for post-1940 federal land acquisitions within a state, federal criminal jurisdiction exists only if the United States formally accepts jurisdiction under 40 U.S.C. § 255; because no acceptance occurred for Camp Claiborne, the federal district court lacked authority to prosecute and sentence the defendants.


Adams v. United States, 319 U.S. 312 (1943)