1984]
POLITICAL ACTIVISTS AND THE GRAND JURY
1183
work of the ISD out of power, but the government's use of the grand jury as an instrument of repression and internment was far from over. G.
THE GRAND JURY TODAY
The use of the federal grand jury by the Department of Justice against the Puerto Rican Independence Movement in the United States and Puerto Rico, clearly illustrates the potential for far reaching abuse of this power in the present. The use of the federal grand jury against the Independence movement in Puerto Rico dates back to 1936, when a grand jury investigating an alleged conspiracy to overthrow the U.S. Government in Puerto Rico subpoenaed numerous officials of the Nationalist Party of Puerto Rico. The grand jury asked the subpoenees for the records of the Nationalist Party. When the then Secretary General, Juan Antonio Correger, came forward claiming to have custody of the records, the subpoenas against the others were dismissed. Correger, however, refused the grand jurors' request to produce the records, claiming that a U.S. federal grand jury had no legitimate jurisdiction in Puerto Rico. 111 As a result of his refusal, Correger received a one year sentence in the federal prison in Atlanta, Georgia. 112 Correger's refusal to recognize the grand jury has survived to the present day as a position of political principle among a broad spectrum of the Independence movement. Independence advocates '. :-:w the U.S. federal grand jury as an illegal instrument of colonial authority whose powers of inquisition they must resist. I 13 The use of the grandjury against the Independence movement in the United States began in response to its growing public exposure and to the emergence of a clandestine pro-Independence organization called the Fuerzas Armadas de Liberacion Nacional (FALN), which had claimed credit for a series of bombings in the United States. I 14 In 1977, a federal grand jury sitting in the Southalso imprisoned. See United States v. Weinberg, supra note 97. See also infra note 120 regarding the imprisonment of Ruerto Rican activists. III Conversation with Juan Antonio Correger, in Guynabo, Puerto Rico (April 1980). For an excellent historical account of the nationalist period, see generally LOPEZ, PUERTO RICAN NATIONALISM (1977). 112 A year later, the same grand jury indicted Correger and six other leaders of the Nationalist Party, including its leader, Harvard educated lawyer Pedro Albizu Compos, for seditious conspiracy to overthrow the U.S. Government in Puerto Rico. They were tried, convicted, and sentenced to ten years in prison. See Albizu v. United States, 88 F.2d 138 (1st Cir. 1937). 113 See supra note 109. 114 See United States v. Torres, 751 F.2d 875, 876-77 (7th Cir. 1984).