Supreme Court
Cases (Summary)
Marbury
v. Madison
Citation: 5 U.S. 137 (1803) Concepts:
Judicial v. Executive Power/Judicial Review
Facts
In his last few hours in office, President John Adams made a
series of “midnight appointments” to fill as many government posts as possible
with Federalists. One of these appointments was William Marbury as a federal justice of
the peace. However, Thomas Jefferson took over as President before the appointment was
officially given to Marbury. Jefferson, a Republican, instructed Secretary of State James
Madison to not deliver the appointment. Marbury sued Madison to get the appointment he
felt he deserved. He asked the Court to issue a writ
of mandamus,
requiring Madison to deliver the appointment. The Judiciary Act, passed by Congress in
1789, permitted the Supreme Court of the United States to issue such a writ.
Issue
Whether the Supreme Court of the United States has the power,
under Article III, Section 2, of the Constitution, to interpret the constitutionality of a
law or statute passed by Congress.
Opinion
The Court decided that Marbury’s request for a writ of
mandamus was based on a law passed by Congress that the Court held to be
unconstitutional. The Court decided unanimously that the federal law contradicted the
Constitution, and since the Constitution is the Supreme Law of the Land, it must reign
supreme. Through this case, Chief Justice John Marshall established the power of judicial
review: the power of the Court not only to interpret the constitutionality of a law or
statute but also to carry out the process and enforce its decision.
This case is the Court’s first elaborate statement of its
power of judicial review. In language which remains relevant today, Chief Justice Marshall
said, “lt is emphatically the province and duty of the judicial department to say
what the law is.” Nowhere in the Constitution does the Court have the power that
Chief Justice Marshall proclaimed. Despite there being no mention of such power in the
Constitution, since 1803, our Nation has assumed the two chief principles of this case:
that when there is a conflict between the Constitution and a federal or state law, the
Constitution is supreme; and that it is the job of the Court to interpret the laws of the
United States.
Fletcher v.
Peck
Citation: 6 Cr. 87 (1810) Concepts: Ex Post
Facto Legislation/Contract Clause
Facts
In 1795, the Georgia legislature sold thirty-five million acres
of Native American land to four land speculating companies for one-half million dollars. In 1796, a newly elected legislature rescinded and
revoked the sale of the land because of widespread fraud and bribery that influenced the
original sale of the thirty-five million acres.
Mr. John Peck purchased some of the land from one of the original
land speculating companies and resold the land to Mr. Robert Fletcher. When Mr. Fletcher learned of the new
legislature’s repeal of the original land sale, he demanded his contract with
Mr. Peck be declared null and void and his money be returned. Mr. Fletcher claimed his sale of land to Mr. Peck
was valid and protected by the Contracts Clause, Article 1, Section 10, of the
Constitution of the United States.
Issue
Can the contract entered into by Mr. Fletcher and Mr. Peck be
invalidated by the new law passed by the Georgia legislature?
Opinion
In a unanimous opinion, the Supreme Court of the United States
ruled that the original land grant was a valid contract despite the fact that it was
corruptly passed by the Georgia legislature. The
Court held that the new Georgia legislature could not annul the land sale ex post facto
(after the fact). The Court noted that nothing in the Constitution allows states to pass
laws which void contracts or land grants made by previous state legislatures. The Constitution prohibits states from passing any
“law impairing the obligation of contracts.”
Dartmouth College v. Woodward
Citation: 4 Wheat. 519 (1819)
Concepts: Contractual Obligations/State
Rights/Private Rights
Facts
Dartmouth College was established in 1769 under a corporate
charter from King George III of England, which was to last “forever.” When
the United States was formed, the agreement with the King became an agreement with the
state of New Hampshire. In 1816, the New
Hampshire state legislature amended (changed) the College’s charter, making it a
state university, enlarging the number of trustees, and revising the educational purpose
of Dartmouth College. The trustees of the
College protested, stating that the original charter was still valid, and sued. Daniel
Webster represented Dartmouth College and argued that such amendments were contrary to the
original charter and therefore could not be changed by the state.
Issue
Whether the Dartmouth College’s private corporate charter
was constitutionally protected against any state law designed to interfere with the nature
and purpose of the original charter.
Opinion
In a 6-1 decision, the Supreme Court of the United States ruled
that the Dartmouth College charter was a contract and was unconstitutionally interfered
with by the new laws enacted by the New Hampshire legislation. Chief Justice Marshall stated that the College
charter was a contract protected by the Constitution and the state of New Hampshire
was bound to respect the original charter.
McCulloch v. Maryland
Citation: 17 U.S. 316
(1819) Concepts:
“Necessary & Proper” Clause/Federal Supremacy v. State Rights
Facts
The state of Maryland brought an action against James William
McCulloch, a cashier in the Maryland branch of the Bank of the United States, for not
paying a tax the state had imposed on the United States Bank.
Issue
Whether the state of Maryland had the right to tax a federal
agency which was properly set up by the United States Congress.
Opinion
In a unanimous decision, the Supreme Court of the United States
ruled that the “power to tax involves the power to destroy,” and that the
federal government’s national bank was immune to state taxation. The Court reasoned
that Congress could set up a United States Bank and write laws “necessary and
proper” to carry out its constitutional power to coin and regulate money.
Gibbons v. Ogden
Citation: 22 U.S. 1
(1824) Concepts:
Interstate Commerce/Federal Supremacy v. State Rights
Facts
Robert Livingston secured from the New York State Legislature an
exclusive twenty-year grant to navigate the rivers and other waters of the State. The
grant further provided that no one should be allowed to navigate New York waters by steam
without a license from Livingston and his partner, Robert Fulton, and any unlicensed
vessel should be forfeited to them. Ogden had secured a license for steam navigation from
Fulton and Livingston. Gibbons originally had been partners with Odgen but was now his
rival. Gibbons was operating steamboats between New York and New Jersey under the
authority of a license obtained from the United States. Ogden petitioned the New York
court and obtained an injunction ordering Gibbons to stop operating his boats in New York
waters.
Issue
Whether the New York statute that prohibited vessels licensed by
the United States from navigating the waters of New York was unconstitutional and,
therefore, void.
Opinion
Writing for the Supreme Court of the United States, Justice
Marshall said that the injunction against Gibbons was invalid because the monopoly granted
by the New York statute conflicted with a valid federal law. The Court used this case to
put forth the position that Congress can legislate and regulate all matters of interstate commerce as long as there
is some commercial connection with another state. While interstate commerce is regulated
by Congress, power to regulate “completely internal” commerce (trade carried on
in a state that does not affect other states) is reserved to the states.
First
Cherokee Indian Case
Cherokee Nation v. Georgia
Citation: 5 Pet. 1 (1831) Concepts: Sovereignty of Indian
Nations/ Reserve Power of States
Facts
In 1791, a federal treaty granted the Cherokee Indians land
within the boundaries of Georgia. In the
1820s the state began to enforce strict laws which were meant to assert control over the
Indians and their land. The Cherokee Nation
filed suit requesting the Supreme Court of the United States to order the state to stop
enforcing these laws. The Georgia officials
refused to participate in the suit. Meanwhile,
Georgia’s governor and legislature executed a Cherokee Indian, Corn Tassel, under the
laws being contested by the Cherokee Nation. This
was in direct defiance of the Supreme Court’s notice to the state of Georgia that it
was looking into the conviction of Corn Tassel, thus furthering the problem.
Issue
Whether the state of Georgia could enforce its state laws upon
the Cherokee nation and deny the constitutional jurisdiction of the Supreme Court.
Opinion
The Supreme Court denied the Cherokees request reasoning it had
no jurisdiction to decide such a case. Chief Justice Marshall wrote, “this is not the
tribunal that can redress the past or prevent the future.”
Second Cherokee Indian Case
Worcester v. Georgia
Citation: 6 Pet. 515 (1832) Concepts: State Powers/Federal Jurisdiction/Tribal
Sovereignty
Facts
A Georgia law required all whites living in Cherokee Indian
Territory to obtain a state license. Two
missionaries refused to obey the state law, were arrested, convicted, and sentenced to
four years of hard labor for violating the state licensing law. They appealed their case to the Supreme Court of
the United States arguing that the laws they had been convicted under were
unconstitutional because states have no power or authority to pass laws concerning
sovereign Indian Nations.
Issue
Whether States had the reserve power to pass laws concerning the
Indian Nations.
Opinion
The Court ruled that the State had no power to pass any laws
affecting the Cherokees because Federal jurisdiction over the Cherokees was exclusive. The missionaries’ convictions were therefore
reversed. This case led to much disagreement
within the three branches of government. The
President of the United States, Andrew Jackson, was rumored to have said that the Chief
Justice has made his decision with this case, now let him enforce it. In what has been described as a political outcome
to this case, the state of Georgia would, in time, pardon the two missionaries.
Dred Scott v. Sanford
Citation: 60 U.S. 393
(1857) Concepts:
Slavery/Question of Citizenship v. Fifth Amendment/Property Rights
Facts
Dred Scott, a slave, was taken by his owner, Sanford, into
northern federal territory. Scott felt that he was free because of the Missouri Compromise of 1820, which excluded slavery
from specified portions of United States territories. When he came back to Missouri, Scott
sued his owner for his freedom.
Issue
Whether Dred Scott, a slave, was a citizen of the United States
and legally entitled to use the courts to sue.
Opinion
The Supreme Court of the United States ruled that slaves were
property, not citizens and, therefore, Dred Scott was not entitled to use the courts. The
Court focused on the rights of the owner, not the slave, saying that black people had no
rights that white people were bound to respect. Justice Taney said that freeing Scott
would be a clear violation of the Fifth Amendment because it would amount to depriving
Sanford of his property without due process of law. He also said that Congress had no
power to prohibit slavery in the territory and that the Missouri Compromise
was unconstitutional.
[Justice Taney is considered one of the most prominent chief
justices; however, Dred Scott has been widely
criticized throughout history. Justice Taney believed that if he decided the case in favor
of Scott, immediate civil war would have resulted. Associate Justice Curtis of
Massachusetts disagreed so strongly with Taney’s decision that he left the Court.]
Ex Parte Merryman
Citation: 17 F. Cas.
144, No. 9487 Concepts: Writ of Habeas Corpus/(Cir. Ct., D.
Maryland, 1861) Executive Power v. Civilian
Due Process
Facts
John Merryman favored the South in the Civil War. A month after
the war began in 1861, he was arrested and jailed for burning railroad bridges. His arrest
was based on a vague suspicion of treason. There was no warrant issued, nor were there any
witnesses nor proof of any illegal action. Merryman wrote to Chief Justice Roger Taney,
asking for a writ of habeas corpus so that his case would be tried in a civilian court.
Chief Justice Taney issued the writ. However, the military commander in charge of
Merryman’s trial ignored the writ, citing President Lincoln’s suspension of
habeas corpus in certain parts of the country.
Issue
Whether the President of the United States has the power to
suspend a writ of habeas corpus without the consent of Congress; and whether Merryman was
deprived of life, liberty, or property without due process.
Opinion
Chief Justice Taney, who was holding circuit court (which Supreme
Court justices did then), challenged President Lincoln’s suspension of the writ of
habeas corpus. The Chief Justice believed that the President drew too much power to
himself without the consent of Congress. He criticized the President for improperly
substituting military authority for civilian authority and emphatically warned that the
people of the United States were “no longer
living under a government of laws, but ... at the will and pleasure of the army officer in
whose military district they happen to be found.”
[Eventually, Merryman was handed over to civilian authorities,
and Congress gave the President the power, which he had previously drawn to himself, to
suspend the privilege of habeas corpus at his discretion during wartime].
Ex Parte Milligan
Citation: 4 Wall. 2
(1866) Concepts: Executive
Powers/Legislative Powers/Civilian Courts
Facts
During the Civil War, President Abraham Lincoln instituted trial
by military commission for civilians in areas where civil courts continued to function. In 1864, L.P. Milligan, a rebel, was tried and
convicted of conspiracy by a military commission in Indiana. He was sentenced to die for his role in a plan to
release and arm Confederate prisoners to invade Indiana.
L.P. Milligan appealed his conviction by the military commission to the Supreme
Court of the United States.
Issue
Whether the President of the United States or the United States
Congress can replace civilian courts with military courts to try civilians.
Opinion
The Supreme Court of the United States unanimously held that the
President acted unconstitutionally when he instituted trial by military commission for
civilians. The Court further reasoned that neither Congress nor the President have the
power to authorize military commissions to try civilians in areas outside actual war
zones. The decision established that martial
law must be confined to theaters of active military operations.
Slaughterhouse Cases
Butchers’ Benevolent Association of New Orleans
v.
The Crescent City Livestock Landing and Slaughterhouse Co.
Citation: 16 Wall. 36 (1873) Concepts: 14th Amendment Rights/Monopolies
Facts
New Orleans butchers charged that the state of Louisiana had
violated their Fourteenth Amendment Rights by granting one company the exclusive rights to
operate a slaughterhouse in New Orleans. The
butchers alleged that the state-granted monopoly to one company deprived them of their
right to earn a living, a right among those privileges and immunities guaranteed by the
Fourteenth Amendment.
Issue
Whether the state of Louisiana’s grant of a monopoly
abridged the privileges or immunities of citizens by depriving them of due process and
property rights granted by the Fourteenth Amendment.
Opinion
The Supreme Court of the United States ruled 5-4 that Louisiana
had not violated the Fourteenth Amendment by granting a monopoly on the slaughterhouse
business to one company for New Orleans. The
Court stated that the right of the other butchers to do business was neither a
“privilege and immunity” protected by the Fourteenth Amendment, nor an aspect of
“property” protected by the due process guarantee of the same amendment. In
this, its first major interpretation of the recently ratified Fourteenth Amendment, the
Court argued that the amendment applied to rights associated with United States
citizenship, not those under state citizenship, and therefore only prevented states from
interfering with the former.
Munn
v. Illinois
Citation: 94 U.S. 113
(1877) Concepts:
Public-Private Property/FreeEnterprise v. State Rights
Facts
Midwestern farmers felt that they were being victimized by the
exorbitant freight rates they were forced to pay to the powerful railroad companies. As a
result, the state of Illinois passed a law that allowed the state to fix maximum rates
that railroads and grain elevator companies could charge.
Issue
Whether the regulation of railroad rates by the state of Illinois
deprived the railroad companies of property without due process of law.
Opinion
The Supreme Court of the United States upheld the Illinois law
because the movement and storage of grain were considered to be closely related to public
interest. This type of economic activity could be governed by state legislatures, whereas
purely private contracts could only be governed by the courts. The Court held that laws
affecting public interest could be made or changed by state legislatures without
interference from the courts. The Court said, “For protection against abuse by
legislatures, the people must resort to the polls, not the courts.”
Civil
Rights Cases
Citation: 109 U.S. 3 (1883) Concepts: The 13th & 14th Amendments/Powers of
Congress
Facts
In 1875, the United States Congress passed the Civil Rights Act
which declared it a crime to deny equal access and enjoyment of public accommodations to
“citizens of every race or color.” However,
most privately owned, but publicly used theaters, hotels, restaurants, trains, and other
such businesses, within several states, continued to deny black customers use of their
facilities. Five separate cases, each from
different states, were merged together to form the Civil Rights Cases. In all five of the cases, the lawsuits were based
upon the Civil Rights Act of 1875 because they alleged continued discrimination.
Issue
Whether the Thirteenth and Fourteenth Amendments provided the
United States Congress power to establish laws barring discrimination in privately owned
accommodations.
Opinion
The Supreme Court of the United States ruled 8-1 that Congress
had overstepped its authority to enforce the Fourteenth Amendment with the passage of the
Civil Rights Act of 1875, and therefore, the act was invalid. The Court cited that the Fourteenth Amendment only
applied to discriminatory action taken by states, not the discriminatory actions taken by
individuals in the private sector. The Court
also reasoned that private discrimination does not violate the Thirteenth Amendment’s
prohibition against slavery and involuntary servitude.
Santa Clara County v. Southern Pacific Railroad
Citation: 118 U.S. 394
(1886) Concepts:
Corporate Tax/State Power to Tax v. Equal Protection
Facts
Santa Clara County taxed the Southern Pacific Railroad. However,
the corporation refused to pay the taxes, claiming that the taxes were assessed at the
full monetary value without the discount that was given to individual property owners for
extremely large mortgages. The Southern Pacific claimed that under the Fourteenth
Amendment, their corporation, which should be treated as an individual, was denied equal
protection under the law.
Issue
Whether corporations should be treated as individuals under the
Fourteenth Amendment; and whether the state of California denied Southern Pacific Railroad
equal protection under the law.
Opinion
The Supreme Court of the United States agreed with the railroad
and upheld the lower court decision that Santa Clara County wrongfully taxed the Southern
Pacific Railroad. Under the Fourteenth Amendment of the Constitution, corporations are
treated as individuals; therefore, their taxes should be assessed at a smaller value, the
same way it is done for individual property owners.
[This case is often cited in other cases because it stands for
the principle that the word person in the
Fourteenth Amendment applies to corporations as well as natural persons and both are
entitled to the equal protection of the laws under the Constitution. Thus, corporations
are now considered legal persons and can sue and be sued.]
Wabash,
St. Louis & Pacific Railway Co. v. Illinois
Citation: 118 U.S. 557
(1886) Concepts:
Individual Property Rights v. State Rights/Commerce Clause
Facts
An Illinois statute imposed a penalty on railroads that charged
the same or more money for passengers or freight shipped for shorter distances than for
longer distances. The railroad in this case charged more for goods shipped from Gilman,
Illinois, to New York, than from Peoria, Illinois, to New York, when Gilman was eighty-six
miles closer to New York than Peoria. The intent of the statute was to avoid
discrimination against small towns not served by competing railroad lines and was applied
to the intrastate (within one state) portion of an interstate (two or more states)
journey.
Issue
Whether a state government has the power to regulate railroad
prices on that portion of an interstate journey that lies within its borders.
Opinion
The Supreme Court of the United States held the Illinois statute
to be invalid and that the power to regulate interstate railroad rates is a federal power
which belongs exclusively to Congress and, therefore, cannot be exercised by individual
states. The Court said the right of continuous transportation from one end of the country
to the other is essential and that states should not be permitted to impose restraints on
the freedom of commerce. In this decision, the Court gave great strength to the commerce
clause of the Constitution by saying that states cannot impose regulations concerning
price, compensation, taxation, or any other restrictive regulation interfering or
seriously affecting interstate commerce.
[One year after Wabash, Congress
enacted the Interstate Commerce Commission (ICC). This Commission had the power to
regulate interstate commerce.]
Chae
Chan Ping v. United States
Citation: 130 U.S. 581
(1889) Concepts:
Treaties/Congressional Powers/lmmigration
Facts
Between 1848, when gold was discovered in California, and the
time of this case, the number of Chinese laborers in the United States greatly increased.
During this short time, the Chinese immigrant population grew to become seventeen percent
of the California population. This threatened American workers’ jobs; in response
Congress passed the Chinese Exclusion Act of 1882. The Act permitted the United States to
regulate the flow of Chinese immigrants into the United States. Chae Chan Ping, a subject
of the Emperor of China and a laborer by trade, lived in San Francisco, California. He
left for China in 1875, but was not allowed to return to the United States in 1888 because
of the new legislation. Ping contended that the Act violated existing treaties with China
and that he should be allowed to re-enter the United States.
Issue
Whether an act of Congress that excluded Chinese laborers from
the United States was a constitutional exercise of congressional power even though the act
conflicted with an existing treaty with China.
Opinion
The Supreme Court of the United States ruled that Congress did
have the right to deny Chae Chan Ping’s re-entry into the United States. Saying that
treaties are equivalent to acts of Congress and can be repealed or amended, the Court
reasoned that it was permissible to exclude the Chinese because the preservation of
independence and the security against foreign aggression are the highest duties of every
nation. All other considerations are subordinate. Congress must have the power to do
whatever it may deem essential in order to maintain and protect the United States. Such
power includes the control over the immigration of aliens and their return to the United
States. The Court decided that Congress had the authority to determine whether certain
foreigners should be excluded.
Chicago,
Milwaukee & St. Paul Railway Co. v. State of Minnesota
Citation: 134 U.S. 418
(1890) Concepts:
Railroad Rates/Procedural Due Process v. State Rights
Facts
In 1887, the state of Minnesota passed an act to regulate common
carriers (i.e railroads). The act declared that any unreasonable charge for service in the
transportation of passengers or property was to be unlawful and prohibited. Certain trade
unions complained that the Chicago, Milwaukee and St. Paul Railway charged some shippers
up to four cents per gallon for the transportation of milk. They believed that these
prices were unreasonable and unlawful under the act.
Issue
Whether states have the authority to regulate the rates which
railroads charge for transportation of passengers or goods.
Opinion
The Supreme Court of the United States invalidated the Minnesota
law because it authorized administrative rate-making without providing for judicial review
(a hearing). The Court held that the state of Minnesota has the power to regulate and
question the reasonableness of rates; however, railroads were entitled to more procedural
protection. The Court upheld the state railway commission’s right to regulate
railroad rates but the commission had to give the railroads an opportunity to question and
be heard if the rates established by the commission were unreasonable.
United
States v. E.C. Knight Co.
Citation: 156 U.S. 1
(1895) Concepts:
Anti-Trust Acts/Congressional Power v. Free Enterprise
Facts
The Sherman Anti-Trust Act, passed by Congress in 1890, was an
attempt to limit the growth of corporate power. Prior to this case, the American Sugar
Refining Co., through stockholder agreements, purchased stock in smaller companies and
eventually controlled 90 percent of the sugar processed in the United States. The federal
government regarded the acquisition of the sugar refining companies as an illegal
restraint of interstate commerce.
Issue
Whether Congress has the authority to regulate manufacturing; and
whether the Sherman Anti-Trust Act outlawed manufacturing monopolies.
Opinion
The Supreme Court of the United States believed that there were
certain aspects of economic life that should be
regulated by the federal government and other aspects that should be left to the states to regulate. Here, where the federal
government sued under the Sherman Act to break up the
large sugar refining monopoly of Knight, the Court held that the federal government could
not regulate refineries since they were
“manufacturing operations” that were not directly related to interstate commerce. The Court reasoned that the
states, under the Tenth Amendment, should have
the right reserved to them to regulate “local activities,” such as
manufacturing. [In subsequent cases, the Court
modified its position and permitted Congress greater regulation of commerce.]
In
Re Debs
Citation: 158 U.S. 564
(1895) Concepts:
Union Strikes/Commerce Clause v. First & Fourteenth Amendments
Facts
Eugene V. Debs, an American railway union officer and one of the
leaders of the Pullman Railroad Car workers’ strike in 1894, refused to honor a
federal court “injunction” ordering him to halt the strike. Debs appealed his
“contempt of court” conviction.
Issue
Whether the federal government has the constitutional authority
to stop railroad workers from striking.
Opinion
The Supreme Court of the United States, in a unanimous decision,
upheld the authority of the federal government to halt the strike. The Court reasoned that
the federal government has “enumerated powers” found in Article 1, Section 8, to
“regulate commerce ... among the several states,” and to establish post offices
and post roads. When the American Railway Union struck, it interfered with the
railroad’s ability to carry commerce and mail which benefited the needs and
“general welfare” of all Americans.
Plessy
v. Ferguson
Citation: 163 U.S. 537
(1896) Concepts:
Separate But Equal/Equal Protection
v. State Rights
Facts
In 1892, Plessy purchased a first class ticket on the East
Louisiana Railway, from New Orleans to Covington,
Louisiana. Plessy, who was of racially mixed descent (one-eighth black and seven-eighths
Caucasian), was a United States citizen and a resident of the state of Louisiana. When he entered the train, he took a seat in the coach
where only whites were permitted to sit. He was told
by the conductor to leave the coach and to find another seat on the train where non-whites
were permitted to sit. Plessy did not move and
was ejected by force from the train. Plessy was sent to jail for violating the Louisiana Act of
1890, which required railway companies to provide “separate but equal” accommodations for white and
black races. Plessy argued that this law was unconstitutional.
Issue
Whether laws which provided for the separation of races violated
the rights of blacks as guaranteed by the
equal protection clause of the Fourteenth Amendment.
Opinion
The Supreme Court of the United States held that the Louisiana
Act, which stated that “all railway companies
were to provide equal but separate accommodations for white and black races” did not violate the Constitution. This law did not take
away from the federal authority to regulate interstate commerce, nor did it violate the Thirteenth
Amendment, which abolished slavery. Additionally, the law did not violate the Fourteenth Amendment,
which gave all blacks citizenship, and forbade states
from passing any laws which would deprive blacks of their constitutional rights. The Court believed that “separate but equal” was
the most reasonable approach considering the social prejudices which prevailed at the time.
[The Plessy doctrine of
“separate but equal” was overturned by Brown
v. Board of Education of Topeka, 347 U.S. 483 (1954) (see p. 24), which held
“separate but equal” to be unconstitutional.]
United States v. Wong Kim Ark
Citation: 169 U.S. 649
(1898) Concepts: Citizenship/Civil Rights/Immigration
Facts
Wong Kim Ark was born in 1873 in San Francisco, California. At the time of his birth, both his parents were
Chinese citizens, but living as resident aliens in San Francisco. Since his birth, Ark had lived in California, but
at age 17, Wong Kim Ark accompanied his parents to China on a temporary visit. Upon his return to the United States, he was
granted re-entry because he was a native-born citizen.
Again in 1894, Mr. Ark traveled to China, but upon returning to the United States,
he was denied entrance on grounds that he was not a United States citizen.
Issue
Whether the United States Customs officers violated Wong Kim
Ark’s Fourteenth Amendment rights, when they denied him re-entry into the United
States.
Opinion
The Supreme Court of the United States, in a 6-2 decision, ruled
in favor of Mr. Ark. The fundamental rule of
citizenship by birth includes all children of resident aliens born in this country. Since he was born in the United States, Mr. Ark
was a citizen. The Chinese Exclusion Act
passed in 1882 by the United States Congress couldn’t apply to Mr. Ark, for he was a
naturalized citizen.
DeLima
v. Bidwell
Citation: 182 U.S. 1
(1901) Concepts: Federalism/Commerce/Imperialism/Colonization/Incorporation
Facts
The DeLima Sugar Importing Company sued the New York City
collector of customs to recover duties on sugar imported from Puerto Rico after 1899, when
Puerto Rico was ceded to the United States. DeLima
charged that The Port of New York City had no jurisdiction to collect duties, since Puerto
Rico was annexed by the United States.
Issue
Whether Constitutional rights and guarantees afforded residents
of the United States extend to residents of new territories.
Opinion
In a 5-4 decision, the Supreme Court of the United States ruled
that when the peace treaty between Spain and the United States was ratified on April 11,
1899, Puerto Rico ceased to be a foreign country, but neither was it part of the United
States, protected by the Constitution of the United States.
The Court ruled the Constitution fully applies only to residents in territories
that have been formally incorporated into the United States through treaties or Acts of
Congress. The Court left it up to the United States
Congress to govern territories.
Northern Securities Company v. United States
Citation: 193 U.S. 197 (1904)
Concepts: Restraints of Trade/Federal
Anti-Trust/Commerce Clause
Facts
The major stockholders of two competing railroad companies set up
a holding company to buy the controlling interest of the two railroads. The Sherman Anti-Trust Act of 1890 forbade
unreasonable restraints on trade. The
constitutionality of the holding company was brought into question by the United States
government during President Theodore Roosevelt’s trust busting campaign.
Issue
Whether the United States Congress had the authority under the
Commerce Clause in the Constitution of the United States to regulate the holding
company’s effort to eliminate competition.
Opinion
The Supreme Court of the United States in a 5-4 decision found
that a holding company formed solely to eliminate competition between the two railroads
was in violation of the Federal Anti-Trust Act because it unreasonably restrained
interstate and international commerce. The Court ruled that the Federal Anti-Trust Act
could apply to any conspiracy which sought to eliminate competition between otherwise
competitive railroads.
Dorr
v. United States
Citation: 195 U.S. 138
(1904) Concepts:
Jury Trial/Rights of the Accused v. Congressional Power Over Territories
Facts
After the Spanish American War in 1898, the United States
obtained the Philippines, Cuba, Guam, and Puerto Rico as territories. In the Philippines,
Dorr was arrested for libel. Dorr was editor of the Manila
Freedom, a radical newspaper opposing the government. Denied a trial by jury, he lost
his case and appealed to the Supreme Court of the United States claiming that his
constitutional right to a trial by jury had been denied.
Issue
Whether a trial by jury is necessary in a judicial proceeding in
the Philippine Islands where the accused person has been denied a jury trial.
Opinion
The Court ruled that a trial by jury in the Philippines, or in
any other United States territory, is not a “constitutional necessity,” and the
conviction was upheld. The Court concluded that the Constitution gives Congress the power
to acquire and govern new territory but does not provide for the right of trial by jury in
those territories. However, Congress could pass a law requiring trial by jury in the
territories. The territorial government of the Philippines did not have to provide a jury
trial in criminal cases unless Congress passed legislation requiring it to do so.
Lochner
v. New York
Citation: 198 U.S. 45 (1905) Concepts: Work Hours Per Week/Individual Property
Rights v. State “Police Powers”
Facts
New York law set limits on how many hours bakery employees could
work. Lochner was convicted and fined fifty dollars for permitting an employee to work
more than the lawful number hours in one week. On appeal, Lochner claimed that the New
York law infringed on his right to make employer/employee contracts.
Issue
Whether a law which limited the number of hours bakery employees
were allowed to work interfered with the bakery owner’s right to make
employer/employee contracts.
Opinion
The Supreme Court of the United States held that even though
states have the power to regulate the areas of health, safety, morals, and public welfare,
the New York law in question was not within the limits of these “police powers”
of the State.
[This decision marked the beginning of the “substantive due
process” era, in which the Court struck down a number of state laws that interfered
with an individual’s economic and property rights. It was overturned twelve years
later in Bunting v. Oregon, 243 U.S. 426
(1917).]
Swift
v. United States
Citation: 196 U.S. 375
(1905) Concepts:
Price Fixing/Free Enterprise v. Congressional Power
Facts
Under various congressional anti-trust acts, Congress had the
power to prevent price fixing and monopolies. Swift and other meat packers arranged to fix
or alter the price of livestock bought and sold in Chicago, in violation of these acts.
Swift argued that it was not involved in interstate commerce since the stockyard
transactions were the middle part of the meat packing process and took place only within
the state.
Issue
Whether the Sherman Anti-Trust Act could bar price fixing by meat
dealers within a state.
Opinion
The Supreme Court of the United States held that although the
price fixing related to stockyard activities which occurred in one state, they were a part
of a “stream of interstate commerce” and, therefore, could be regulated by the
federal government under the commerce clause of the United States Constitution.
Muller
v. Oregon
Citation: 208 U.S. 412
(1908) Concepts:
Employee-Employer Contracts/Tenth Amendment v. Fourteenth Amendment
Facts
In 1903, the state of Oregon passed a law prohibiting women from
working in factories or laundries more than ten hours in any day. In 1905, a suit was
filed against Curt Muller for making Mrs. E. Gotcher work more than ten hours in one day.
Found guilty, Muller took his case to the Supreme Court of the United States, charging
that he was wrongly convicted because the legislation of the state of Oregon was
unconstitutional. He believed that his Fourteenth Amendment rights were infringed upon by
his inability to make his own hours for his employees.
Issue
Whether the state of Oregon, through its regulation of
women’s work hours, violated the “privileges and immunities” clause of the
Fourteenth Amendment by forbidding the employment of women for more than ten hours a day
in laundries and factories.
Opinion
The Court held that the Oregon law that barred women (who were
viewed as a weaker class and in need of special protection) from certain factory and
laundry work to be correct and sustained the legislation. The Court distinguished the Lochner case,
where an employer’s “liberty to contract” outweighed the state’s
interest to regulate bakery employees’ hours, from this case, which took into account
the physical differences between men and women. The Court took judicial notice (based upon
a famous brief submitted by then-lawyer, Louis D. Brandeis) of the belief that
“women’s physical structure and the function she performs ... justify special
legislation restricting the conditions under which she should be permitted to toil.”
Weeks
v. United States
Citation: 232 U.S. 383
(1914) Concepts:
Search and Seizure/ “Police Powers”/Exclusionary Rule
Facts
Fremont Weeks was suspected of using the mail system to
distribute chances in a lottery, which was considered gambling and was illegal in
Missouri. Federal agents entered his house, searched his room, and obtained papers
belonging to him. Later, the federal agents returned to the house in order to collect more
evidence and took letters and envelopes from Weeks’ drawers. In both instances, the
police did not have a search warrant. The materials were used against Weeks at his trial
and he was convicted.
Issue
Whether the retention of Weeks’ property and its admission
in evidence against him violated his Fourth Amendment right to be secure from unreasonable
search and seizure and his Fifth Amendment right not to be a witness against himself.
Opinion
The Supreme Court of the United States unanimously decided that
as a defendant in a criminal case, Weeks had a right to be free from unreasonable search
and seizure and that the police unlawfully searched for, seized, and retained Weeks’
letters. The Court praised the police officials for trying to bring guilty people to
punishment but said that the police could not be aided by sacrificing the fundamental
rights secured and guaranteed by the Constitution.
[This decision gave rise to the “Exclusionary Rule.”
This meant that evidence seized in violation of the Constitution cannot be admitted during
a trial.]
Hammer
v. Dagenhart
Citation: 247 U.S. 251
(1918) Concepts:
Child Labor/Congressional Powers v. State Rights/Commerce Clause
Facts
In 1916, Congress passed the Child Labor Law, which prohibited
the interstate transportation of products made by companies that employed young children
who worked long hours.
Issue
Whether congressional powers under the commerce clause extended
far enough to prohibit the interstate transportation of products made in factories in
which underage children worked.
Opinion
In a 5-4 decision, the Supreme Court of the United States held
that the Child Labor Law of 1916 was unconstitutional. The Court reasoned that Congress
was trying to regulate child labor laws by using the commerce clause and that the
employment of children was not directly related to interstate commerce. The Court felt
that Congress should not impinge upon the states’ right to oversee child labor by
using its power to regulate commerce so as to indirectly regulate child labor.
Schenck
v. United States
Citation: 249 U.S. 47
(1919) Concepts:
Clear & Present Danger/Free Speech v. Congressional War Powers
Facts
Charles T. Schenck and Elizabeth Baer, charged with conspiring to
print and circulate documents intended to cause insubordination within the military, were
convicted of violating the Espionage Act of 1917. The act made it a crime to
“willfully cause or attempt to cause insubordination, disloyalty, mutiny, or refusal
of duty in the military ... or to willfully obstruct the recruiting service of the United
States.” Schenck appealed the conviction to the Supreme Court of the United States,
claiming all his actions were protected by the First Amendment.
Issue
Whether Schenck’s and Baer’s First Amendment right to
freedom of speech were violated when they were convicted of conspiring to obstruct the
recruitment and enlistment of service.
Opinion
The Court unanimously upheld the conviction of Schenck, not for
violation of the Espionage Act, but rather for conspiracy to violate it. The Court found
that the First Amendment did not apply in this case, and that Schenck’s speech was
not constitutionally protected because it posed a “clear and present danger” to
the country. The nation was involved in World War I, and the Court saw Schenck’s
speech and action as counter-productive to the national war effort. The Court reasoned
that certain speech could be curtailed, using the example of a situation where one cannot
yell “fire” in a crowded theatre.
Debs
v. United States
Citation: 249 U.S. 211
(1919) Concepts:
Free Speech v. Congressional War Powers
Facts
Eugene V. Debs, a well-known socialist, gave a public speech to
an assembly of people in Canton, Ohio. The speech was about the growth of socialism and
contained statements which were intended to interfere with recruiting and advocated
insubordination, disloyalty, and mutiny in the armed forces. Debs was arrested and charged
with violating the Espionage Act of 1917.
Issue
Whether the United States violated the right of freedom of speech
given to Debs in the First Amendment of the United States Constitution.
Opinion
The Supreme Court of the United States upheld the lower
court’s decision in favor of the United States. The Court said that Debs had actually
planned to discourage people from enlisting in the Armed Forces. The Court refused to
grant him protection under the First Amendment freedom of speech clause, stating that Debs
“used words [in his speech] with the purpose of obstructing the recruiting
service.” Debs’ conviction under the Espionage Act would stand, because his
speech represented a danger to the safety of the United States.
Powell
v. Alabama
Citation: 287 U.S. 45
(1932) Concepts:
Right to Counsel/Due Process
Facts
In what is known as the “First Scottsboro Case” nine
illiterate, young black men were charged with raping two white girls on a freight train
passing through Alabama. Their trial was held
in Scottsboro, Alabama. Under Alabama law,
rape is a Capital offense (a crime punishable by death).
On the first day of the trial, the defendants’ attorney withdrew from the
case; the judge then appointed members of the local bar association, most of whom then
withdrew from the case. Although two attorneys did represent the accused, they did so
without having time to investigate the case and with only a half hour of consultation with
the defendants. All defendants were
convicted.
Issue
Were the defendants denied the right to counsel and due process
within the Fourteenth Amendment if they were not given the opportunity to consult with a
lawyer in a timely fashion to prepare for their defense?
Opinion
In a 7-2 decision, the Supreme Court of the United States
reasoned that because the defendants were ignorant, illiterate, and young; surrounded by
public hostility; under close surveillance by the military and in deadly peril of their
lives; the failure of the trial court to give them reasonable time and opportunity to
secure counsel and prepare for trial was a clear denial of due process. As a result of this case, states were required to
appoint counsel for poor people in all capital cases, and in non-capital cases where
denial of counsel would result in an unfair trial. [See Gideon v. Wainwright (1963) (p. 28) for the further
expansion of a defendant’s right to counsel.]
Schechter Poultry Corp. v. United States
Citation: 295 U.S. 495
(1935) Concepts:
Congressional Power v. Presidential Power/ Commerce Clause/“Sick Chickens”
Facts