Hayburn's Case
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| Hayburn's Case | ||||||||||
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| Decided August 11, 1792 |
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| Holding | ||||||||||
| Non-judicial duties cannot be assigned to federal courts in their official capacity. | ||||||||||
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| Chief Justice: John Jay Associate Justices: James Wilson, William Cushing, John Blair, James Iredell, Thomas Johnson |
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| Per curiam. |
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| Laws applied | ||||||||||
| U.S. Const., Art. III | ||||||||||
Hayburn's Case, 2 U.S. 409 (1792)[1], was a case in which the Supreme Court of the United States held that non-judicial duties could not be assigned to federal courts in their official capacity. This was the first time the court addressed the issue of justiciability.
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[edit] Facts and procedural history
In 1792, Congress enacted legislation requiring the United States Circuit Courts to hear disability pension claims by veterans of the American Revolution.[2] United States Attorney General Edmund Randolph moved for mandamus to command the Circuit Court of Pennsylvania to proceed in the petition of William Hayburn, who had applied for a pension from the U.S. government. The Circuit Court first denied the motion. Randolph then altered his theory of the case, arguing that he was bringing the motion on Hayburn's behalf, and at the behest of an act of Congress which provided for the settlement of certain claims against the United States which had previously been barred by the statute of limitations. The Circuit Court expressed doubt about their jurisdiction over the matter, and took the matter under advisement.
[edit] Decision
The court, quoting from the opinions of three Circuit Courts (Pennsylvania, New York and North Carolina), explained why it could not hear the petition for mandamus. Since the United States Constitution established three separate and independent branches of government (legislative, executive, and judicial, respectively), neither Congress nor the Executive Branch could assign duties to the judiciary which were not truly judicial in nature. The court characterized the duties assigned to them by the act as administrative rather than judicial, because the case had not come before the court as an ordinary case or controversy would have, an issue which would be revisited by the court more than a century later in Muskrat v. United States. Furthermore, the court's decision in this matter would not have been final, as it would have been subject to review by the United States Secretary of War and then by Congress itself, rather than going through the ordinary appellate process before an Article III judge. The court concluded that the practices of the King's Bench and Court of Chancery in England would provide guidance for the practices of the Supreme Court, subject to its own alterations.
[edit] See also
[edit] References
- ^ 2 U.S. 409 Excerpted version of the opinion from "The Founders' Constitution" at University of Chicago
- ^ Hall, Kermit L. ed. The Oxford Companion to the Supreme Court of the United States, Second Edition. Oxford University Press, 2005. ISBN 0195118839 p. 427.
