Grafton v. United States, , was a United States Supreme Court case in which the court held that the Double Jeopardy Clause is not violated when the first conviction came from a court without jurisdiction to try the offense. Also, the separate sovereigns exception to the Double Jeopardy Clause does not apply in a U.S. territory because an insular area is not a sovereign state.
After a soldier stationed in the Philippine Islands territory was court-martialed on a charge of manslaughter, he was acquitted. After that, he was indicted by the provincial court in Iloilo on murder charges. The soldier plead autrefois acquit to assert double jeopardy as a defense. The court rejected his plea. On appeal, that rejection was reversed and the defendant was released.
The Supreme Court issued an opinion on May 27, 1907.