1803 United States Supreme Court case
Stuart v. Laird
, 5 U.S. (1 Cranch) 299 (1803), was a case decided by
United States Supreme Court
notably a week after its famous decision in
Marbury v. Madison
.
Stuart
dealt with a judgment of a
circuit judge
whose position had been abolished by the repeal of the
Judiciary Act of 1801
. Stuart's lawyer was Charles Lee, who also represented
William Marbury
. John Laird asked the Supreme Court to uphold the judge's ruling. Stuart's team argued that only the court rendering a judgment could enforce it and that the
Judiciary Act of 1802
had been unconstitutional, to which Stuart lost on both accounts. The Court
reviewed
and upheld the Judiciary Act of 1802 and averted a dangerous showdown between the
legislative
and the
judicial
branches of the
United States government
.
Background
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The case involved the Judiciary Act of 1801, which created a number of federal judgeships, who were called "
midnight judges
" since the Act had been passed by the
lame-duck
members of the
Federalist Party
during its final days in office. The Act established new circuit court judges to hear intermediate appeals.
As a result, Supreme Court justices would no longer have to "ride circuit," which entailed substantial and often-dangerous travel, to sit with district (trial) court judges to hear appeals throughout the nation. Soon after its passage, the Act was replaced by the
Repeal Act
of March 8, 1802. In passing the Judiciary Act of 1802, Congress "also postponed the next term of the Supreme Court until 1803," which prevented the Court from ruling on the Act's constitutionality until after going into effect, according to law professor William Nelson. Federalists attacked the
Democratic-Republican Party
's new legislation by arguing that federal judges were appointed for life and so could not be constitutionally removed by the Repeal Act. The Judiciary Act of 1802 reinstated circuit courts but also resurrected the practice of circuit riding. Many thought the 1802 Act to be unconstitutional. One of them was newly-appointed Chief Justice
John Marshall
, who argued that justices should not have to preside over circuit courts unless they were commissioned as circuit court judges. He wrote of the other justices, "I am not of opinion that we can under our present appointments hold circuit courts, but I presume a contrary opinion is held by the Court and, if so, I shall conform to it."
[
citation needed
]
Justice
Samuel Chase
agreed with Marshall, but the other justices disagreed.
Decision
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With Marshall not participating but very active behind the scenes, Justice
William Paterson
held for a unanimous Court that Congress had the authority under the Constitution both to establish and to abolish lower federal courts.
Aftermath
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Although the Court sustained the
Judiciary Act of 1802
, the issue of circuit riding was substantially lessened because the Act effectively made circuit riding optional by requiring only one federal judge for a quorum on any circuit court. As a result, Supreme Court justices could rely on district court judges to hear intermediate appeals. That flexibility proved crucial to the demise of circuit riding. By the 1840s, the justices had all but stopped holding circuit courts.
Scholars such as
Bruce Ackerman
have pointed to the decision as part of the opposition Federalist Court's accommodation of the new political regime.
See also
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References
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- Ackerman, Bruce (2005).
The Failure of the Founding Fathers: Jefferson, Marshall, and the Rise of Presidential Democracy
. Cambridge: The Belknap Press of Harvard University.
ISBN
978-0-674-01866-2
.
- Nelson, William E. (2000).
Marbury V. Madison: The Origins and Legacy of Judicial Review
. University Press of Kansas. p. 58.
- Pohlman, Harry L. (1995).
Constitutional Debate in Action
. HarperCollins. p. 21.
- Randolph, Mark Lee (1992).
The judicial activism and historical importance of
Stuart v. Laird
. Charlottesville, VA: M.A.-Thesis.
OCLC
26797948
.
- Smith, Jean Edward
(1996).
John Marshall: Definer Of A Nation
. New York: Henry Holt & Company.
ISBN
978-0-8050-1389-4
.
- Ward, Artemus
(2003).
Deciding to Leave: The Politics of Retirement from the United States Supreme Court
. Albany, NY: SUNY Press.
ISBN
978-0-7914-5652-1
.
Further reading
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- James M. O'Fallon,
The Case of Benjamin More: A Lost Episode in the Struggle over Repeal of the 1801 Judiciary Act
, 11
Law & Hist. Rev.
43 (1993).
External links
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