The Federal Courts and their Jurisdiction in the Amistad Case
U.S. District Court for the District of Connecticut
The Amistad case entered the federal judiciary through the district court of Connecticut, and it was the court’s judge, Andrew Judson, who ruled that the Africans held in custody were not slaves under Spanish law and therefore could not be returned to the planters in Cuba.
The Judiciary Act of 1789 established the federal district courts as trial courts with jurisdiction over maritime commerce and the nation’s trade laws – that branch of law known as admiralty. The district courts also exercised jurisdiction over minor criminal cases and small suits involving the government, although in the first half of the nineteenth century, most of the district court cases, particularly in a coastal state like Connecticut, concerned admiralty. The Amistad case was introduced into the federal courts as an admiralty matter.
U.S. Circuit Court for the District of Connecticut
The U.S. Circuit Court in Connecticut exercised jurisdiction over three separate components of the judicial proceedings related to the Amistad. It considered the indictment of the Mende on charges of piracy and murder, it ruled on the writs of habeas corpus requesting the release of the Mende from federal custody, and it heard the U.S. attorney’s appeal of the district court’s decision that the Mende were not slave property under the laws of Spain. After the circuit court issued a decree upholding the district court decision, the U.S. attorney appealed that decree to the Supreme Court. The circuit court also was responsible for issuing the decree that freed the Mende following the Supreme Court decision.
The U.S. circuit courts were established by the Judiciary Act of 1789 to serve as the most important trial courts in the federal judiciary. These courts, which operated until 1911, had jurisdiction over most federal crimes, over suits between citizens from different states (known as diversity jurisdiction), and over most cases in which the federal government was a party. The circuit courts also heard some appeals from the district courts, including appeals related to admiralty disputes concerning amounts greater than $300. Prior to 1869, the circuit courts had no judges of their own. Each justice of the Supreme Court was assigned to a regional circuit and, along with the local district judge, presided over the circuit court that met in each district within the circuit.
Supreme Court of the United States
In the final stage of the Amistad case, the Supreme Court of the United States declared the Mende to be free and ordered their immediate release from federal custody. The Amistad case went before the Supreme Court on appeal from the circuit court’s decree. The U.S. attorney in Connecticut challenged that decree, which upheld the district court decision that the Mende on the Amistad were not slaves under Spanish law. Justice Joseph Story’s opinion for the Supreme Court agreed with the earlier courts’ decisions that the Mende were not slaves and could not be returned to Cuba. The Court overturned that portion of the earlier decision that ordered the transfer of the Mende to the President for return to their homes in West Africa.
The Supreme Court was established by Article III of the Constitution, which granted the Court limited jurisdiction. The Constitution also authorized Congress to grant the Supreme Court jurisdiction over appeals, and Congress provided for various types of appeals from state and federal courts. According to the Judiciary Act of 1789, any U.S. circuit court decree in a civil case concerning a matter worth more than $2000 could be appealed to the Supreme Court.
From an initial authorization of six justices on the Supreme Court, Congress by 1837 had expanded the number of seats on the Court to nine.
Amistad: The Federal Courts and the Challenge to Slavery — Historical Background and Documents