Balzac V. Porto Rico - Facts and Lower Court Proceedings

Facts and Lower Court Proceedings

Jesús M. Balzac edited the newspaper El Baluarte. Balzac wrote an article referring indirectly to the colonial governor at the time, Arthur Yager; the article was considered libelous by the authorities. Pursuant to the Jones Act of 1917, which granted Puerto Ricans American citizenship among other guarantees, Balzac sought jury trial under the Sixth Amendment. In denying the request for jury trial, the Supreme Court of Puerto Rico relied on two 1918 decisions by the United States Supreme Court: People v. Tapia, 245 U.S. 639 (1918), and People v. Muratti, also at 245 U.S. 639 (1918). These two per curiam decisions cited the earlier Insular Cases and held that provisions of the Bill of Rights were inapplicable to Puerto Rico even after the passage of the Jones Act.

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