People v Godfrey
17 Johns. 225 (1819)

United States Territory in New York

In The Founder's Constitution, an anthology of writings (letters, records of debates and early cases) relating to the Federal Constitution, Chief Judge Spencer’s opinion in People v Godfrey is included as Document 17 of the materials underlying Article 1, Section 8, Clause 17 (Jurisdiction).

On August 25, 1818, William Godfrey, a soldier stationed at Fort Niagara, was on duty as an orderly sergeant. He was given an order to place a fellow soldier, Thomas Branaghan, in a place of punishment known as the Black Hole. Branaghan resisted Godfrey's efforts to confine him, and when finally imprisoned, remonstrated with Godfrey using "bitter epithets." Godfrey became enraged and struck out at Branaghan with a backhanded thrust of his musket. The musket's bayonet wounded Branaghan who shortly afterwards died from his injuries.

Godfrey was brought to trial at the Niagara County Court of Oyer and Terminer. Immediately, he challenged the jurisdiction of the court, asserting that because the injury that caused Branaghan's death had occurred within a fort of the United States Government, only the federal courts had power to hear the case. Although Justice Platt allowed the trial to continue and Godfrey was found guilty, he deferred Godfrey’s sentencing until the jurisdictional issue had been decided by the New York Supreme Court of Judicature.

In the Supreme Court, Attorney General Oakley represented the People while Godfrey was represented by Daniel Cady. The arguments focused on the history of the fort at Niagara which had originally belonged to France, was captured by the British in 1759, and was transferred from France to Britain under the 1763 Treaty of Paris. Following the Revolutionary War, the right of the British Crown to the territory comprising the State of New York became vested in the People of New York, in full sovereignty. The Treaty of 1783 recognized the boundaries of New York State, and the Articles of Confederation expressly reserved the sovereignty of each State. The fort itself was surrendered to the United States under the Treaty of 1794 and since that time it had been possessed and garrisoned by the United States. The Supreme Court held that the fort was subject to the jurisdiction of the State since the lands upon which it stood had not been ceded to the United States. Chief Justice Spencer wrote the opinion of the Court in which he stated that it was beyond all doubt that the United States acquired no territorial rights to any portion of the State of New York under the treaties of 1783 and 1794. When Great Britain withdrew its garrisons, the forts became the property of the several States within whose limits the garrisons were located. The occupation of the fort by United States troops since its evacuation by the British under the treaties could neither be considered as evidence of the right of the federal government to the post itself nor an act hostile to the rights of the State of New York. The Court was "perfectly satisfied that the jurisdiction of this state attaches on the crime, and extends to the person of the prisoner, and nothing remains but that judgment be passed upon him according to law."


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