State Vs Nguyen
Supreme Court
Facts:
Petitioners, Khanh Phuong Nguyen, and Tuyet Mai Thi Phan were convicted in the District Court of Guam for planning to import, importing, and attempting to possess with objectives of distributing methamphetamine. This was an infringement to several chapters of the United States Constitution such as 952(a) and 963, 952(a) and 960, and 841(a) respectively. In 1999, a drug-detection was carried out at the main postal facility of Guam, which gave the lead to Phan who was a U.S citizen living in Guam. The Customs Officers legally opened the express mail package in which they found five cylinders containing 443.8 grams of 97% pure d-Methamphetamine Hydrochloride.
The Officers planned for the transportation of the package to the address given but substituted the content with rock salt. The cylinders were painted with clue spray which would alert the officers when they will be opened. During the process, Phan claimed her package at the post office. She took a long route back home so that she could dispose of the packaging. She then reached her apartment where Nguyen was waiting for her. Nguyen was a Vietnam citizen who legally resided in Guam. On opening the package, signals were sent to the officers who found the two petitioners with the opened packages while Nguyen had the color of the spray. This was evidence that she was an accomplice of Phan. More evidence was found in Nguyen’s apartment where the officers recovered small volumes of Methamphetamine.
Guam territory is not incorporated in the United States. Both petitioners were legally living in Guam up to the time of their arrest. Their case was presented in the territorial court of the District Court of Guam which was created by Congress under Article IV, section 3, clause 2 of the U.S Constitution. The presiding judge to the case was a district court judge under Article IV. The panel sitting of the court of appeal, which collectively affirmed the decision of Guam’s District Court, consisted of Chief Judge Schroeder, Judge Goodwin and Designated Chief District Judge Munson of Northern Mariana Court who is an Article IV judge.
Issue:
1. Was the judgment an insightful implication on the constitutional system of governance?
2. Does the case involve structural protections under Article III that surpass the individual rights of the petitioners?
Decision:
1. No. The petitioners do not present any evidence to show that the Chief Judge of the Ninth Circuit had any intentions to establish an argument about the branches of government under the constitutional articles II, III, and IV. Furthermore, the constitutional avoidance principles allowed the Chief Judge to designate Chief Judge Munson since he did not intend to presume power proscribed to him. Additionally, the constitution should not be criticized without need. The concern of the petitioners could have been addressed in an appeal to rehear the case in the court of appeal but they did not do so.
2. No. The Supreme Court has long declared that the residents of the unincorporated territories such as Guam were not under the protection of Article III. Therefore, the petitioners did not enjoy this constitutional protection and no requirements suggested that their appeals must be presented before an Article III compliant panel. The case also consisted of an error made by a judge in the independent judicial department. This indicated that the error was to be collected internally.
Reasons:
The Supreme Court focused on the statutory provisions of the Federal Judicial Circuits. Section 292(a) of Title 28 of the U.S.C suggests that the Chief Judge of a circuit may designate and assign one or more district judges to sit in the appellate panel whenever the activities of the court require that. Hence, he saw the need to incorporate an Article IV judge in the court of appeal. Similarly, the intentions of the Chief Judge appointing Judge Munson were good since he headed the District Court of Northern Mariana Islands, which was within the Ninth Circuit. Referring to these sections of the constitution, the petitioners did not have evidence that the judge had made a mistake in appointing an Article IV judge, thus there were no bases for their petition of the case.
Appointing Chief Judge Munson to an appellant panel of the territory was not a plain statutory error. In law, a plain error must affect the substantial rights of the petitioners and the fairness, integrity or public reputation of judicial proceedings. Although the judge made an error in appointing a territorial district judge, Title 28 does not define a district judge. Many judges in the Hawaii territory had sat on the Ninth Circuit in the mid-1950s thus proving that the error was not plain. Equally, it did not affect the substantial rights of the petitioners. Decisions in the case of Johnson vs State in 1997 describe an error to be plain if it is affecting the structure of the proceedings of a case. In this case, inclusion of Chief Judge Munson did not affect the rulings since the judges had enough evidence to pass the judgment. Thus, there was fairness and integrity during the court sessions.
The court of appeal consisted of two Article III judges and the Chief District Judge Munson. In the petition, the petitioners complained of unfair judgment. To them, if the trial had been presented before an Article III panel tribunal, the judgment would favorable. They try to establish the prejudice by evaluating the potential influence Judge Munson brought to the panel. However, evidence of biases and inability to fairly and professionally analyze their arguments on the plea were the only factors which could make the judgment to be reconsidered according to the statutes. Since the majority of the judges in the appellant panel were Article III judges, the absence of Judge Munson could not have brought any significant change to the decision made. Therefore, the judgment was fair.
The petitioners were not protected by Article III since their case was within an unincorporated territory of the United States. The law allows territory courts to hear and decide on territory cases and controversies falling within the enumeration of Article III with exclusion of its restrictions. The constitution does not limit the trial and appellate courts to the principle of Article III. In fact, the state allows all courts to decide on federal law within their jurisdictions. The petitioners, therefore, were not under the protection since they had committed a crime in the U.S and were also convicted in a territory within the State. The appeal was also done in the territory of Guam and it tackled cases that only originated from that territory. Thus the petition of the judgment from the court of appeal had weak bases.
References
https://www.justice.gov/osg/brief/nguyen-v-united-states-brief-merits
