 Section 22 of the Judiciary Act of 1789 authorized writs of error from the circuit courts only in civil cases . The District of Columbia Organic Act of 1801 — which created the United States Circuit Court of the District of Columbia and granted it jurisdiction over crimes committed within the federal district — did not explicitly limit writs of error from the D.C. circuit court to civil cases , except insofar as it required an amount in controversy . Although the Court reached the merits of a criminal writ of error from the D.C. circuit court in United States v. Simms ( 1803 ) , without any discussion of the jurisdictional issue , in United States v. More ( 1805 ) , the Court held that it had no such jurisdiction . More held that Congress 's piecemeal statutory grants of appellate jurisdiction to the Court operated as an exercise of Congress 's power under the Exceptions Clause , eliminating all jurisdiction not explicitly granted . 
