Ogden v. Saunders

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Ogden v. Saunders
Supreme Court of the United States
Argued January 18, 1827 Decided February 19, 1827
Full case name: Ogden, Plaintiff in Error v. Saunders, Defendant in Error Citations: 25 U.S. 213; 6 L. Ed. 606; 1827 U.S. LEXIS 394; 12 Wheat. 213 Prior history: Court rules for Ogden; brought before Supreme Court on writ of error
Holding
New York law on bankruptcy did not violate the United States Constitution.
Court membership
Chief Justice: John Marshall Associate Justices: Bushrod Washington, William Johnson, Gabriel Duvall, Joseph Story, Smith Thompson, Robert Trimble
Case opinions
Majority by: Washington Joined by: Johnson, Thompson, Trimble Dissent by: Marshall Joined by: Duvall, Story
Laws applied
Obligation of Contracts Clause

Ogden v. Saunders, 25 U.S. 213 (1827), was a United States Supreme Court case that determined the scope of a bankruptcy law in contrast to a clause of the Constitution of the United States. It was the only decision from which Chief Justice John Marshall dissented during his tenure on the court.^[1]

[edit] Parties Involved

• Saunders: A citizen of Kentucky demanding payment in accordance with a contract.
• Ogden: A citizen of Louisiana who lived in New York at the signing of the contract and claimed bankruptcy as a defense under a New York bankruptcy law passed in 1801.

[edit] Ruling

The main issue of the case was whether or not the New York law violated the Obligation of Contracts Clause of the Constitution. It hinged on whether Congress had exclusive power to pass bankruptcy laws, which itself depended on what was meant by the clause prohibiting states from passing laws impairing the "obligations of contracts." The court's decision, authored by Justice Bushrod Washington, found that the clause prevented states from passing only laws affecting contracts already signed; laws that affected future contracts were construed to become part of the contracts themselves. Since the statute was part of the conditions of any prospective contract, the parties to the contract were presumed to have considered the law in signing the contract; the obligation, then, incorporated the possibility of bankruptcy rather than being impaired by it. The other three Justices joining the Majority were William Johnson, Smith Thompson, and Robert Trimble. ^[2]

Chief Justice John Marshall authored the dissenting opinion. He held that the Contract Clause gave the federal legislature the exclusive power over bankruptcy laws, rejecting the argument that state laws became part of contracts signed within the state thereafter. Marshall was joined in his dissent by Associate Justices Gabriel Duvall and Joseph Story. ^[3]

[edit] References

1. ^ Ariens, Michael. "John Marshall."
2. ^ "FindLaw for Legal Professionals."
3. ^ Michaelsen, Scott. "Cooper's Monikins."