## Facts

- A federal grand jury in the District of Vermont indicted Congressman Matthew Lyon under the Sedition Act of July 14, 1798, for allegedly publishing writings intended to bring the President and U.S. government into contempt.
- One count alleged Lyon authored and published a political piece accusing the executive of a “continual grasp for power” and seeking “ridiculous pomp” and “selfish avarice,” and of removing officials for independent views.
- Another count alleged Lyon published a letter attributed to a French diplomatic figure describing the President’s address as “bullying” and the Senate’s reply as “stupid.”
- Lyon did not substantially dispute the acts of publication but challenged the court’s authority and argued the publications were not criminal; he also asserted the truth of the statements.
- The case was tried in the U.S. Circuit Court for the District of Vermont before Justice William Paterson riding circuit, and the reported decision consists chiefly of the judge’s instructions to the jury.

## Issues

1. Whether, in a federal seditious libel prosecution, the jury may consider the constitutionality of the Sedition Act.
2. What questions are for the jury under the Sedition Act—particularly whether the defendant published the writings and whether he acted with “seditious” intent.

## Decision

- The court instructed that the jury had no role in deciding the constitutionality of the Sedition Act; that issue was for the court.
- The jury’s task was limited to determining whether Lyon published the charged writings and, if so, whether he published them “seditiously,” meaning with intent to make the government and President “odious and contemptible” and bring them into disrepute.
- Lyon was convicted under the Sedition Act and sentenced to imprisonment and a fine.

## Legal Principles

- In a federal criminal prosecution, the constitutionality of the statute is a question of law for the court, not a question for the jury.
- Under the Sedition Act framework applied at trial, the jury determines (1) publication and (2) whether publication was accompanied by the prohibited intent to bring the government or President into contempt or disrepute.
- The jury is to apply the law as given by the court rather than treat the case as an occasion to reject the statute on constitutional grounds.

## Conclusion

The court’s jury charge treated the Sedition Act as binding law and confined the jury to deciding publication and seditious intent, while reserving constitutional questions to the judge, an approach that supported conviction for sharp political criticism of federal officials.


Lyon’s Case, 15 F. Cas. 1183 (C.C.D. Vt. 1798) (No. 8,646)