## Facts

- Luis M. Sánchez Valle and Jaime Gómez Vázquez each sold a firearm to an undercover Puerto Rico police officer.
- Puerto Rico charged each defendant under territorial law for illegally selling firearms.
- While the territorial charges were pending, the federal government indicted each defendant for analogous federal firearms offenses based on the same transactions.
- Both defendants pleaded guilty to the federal charges.
- The defendants moved to dismiss the pending Puerto Rico prosecutions under the Double Jeopardy Clause, arguing the federal convictions barred a second prosecution for the same conduct by the same sovereign.
- Puerto Rico trial courts dismissed the territorial indictments; intermediate appellate review reinstated them; the Supreme Court of Puerto Rico held double jeopardy barred the Commonwealth prosecutions.
- The U.S. Supreme Court granted review.

## Issues

1. Whether Puerto Rico and the United States are “separate sovereigns” under the dual-sovereignty doctrine, permitting successive prosecutions for the same conduct under equivalent criminal laws.
2. Whether Puerto Rico’s authority to prosecute criminal offenses ultimately derives from an independent source or from Congress for Double Jeopardy purposes.

## Decision

- The Court affirmed the judgment that the Commonwealth prosecutions were barred.
- Puerto Rico and the United States are the same sovereign for Double Jeopardy purposes because their prosecutorial authority originates from the same ultimate source.
- Because the defendants had been federally convicted for the same conduct, Puerto Rico could not prosecute them under equivalent territorial offenses.
- Concurring opinions questioned aspects of the dual-sovereignty doctrine and its historical basis.
- The dissent would have treated Puerto Rico’s post-constitution governmental authority as sufficiently independent to qualify as a separate sovereign.

## Legal Principles

- Under the dual-sovereignty doctrine, successive prosecutions for the same conduct are permissible only when brought by separate sovereigns.
- “Sovereignty” in this setting turns on the “ultimate source” of the entity’s power to prosecute, not the degree of local self-government.
- States qualify as separate sovereigns because their prosecutorial authority traces to pre-existing, independent sovereignty preserved by the constitutional structure.
- Territorial governments, including Puerto Rico, do not qualify as separate sovereigns when their authority to enact and enforce criminal law ultimately flows from congressional authorization under federal power.
- Puerto Rico’s adoption of its constitution, though reflecting self-rule, did not create an independent ultimate source of prosecutorial power distinct from Congress.

## Conclusion

The Court held that Puerto Rico and the United States derive prosecutorial authority from the same ultimate source and therefore are not separate sovereigns under the Double Jeopardy Clause; a federal conviction barred Puerto Rico from bringing a second prosecution for the same conduct under equivalent laws.


Puerto Rico v. Sánchez Valle, 579 U.S. 59 (2016)