Ex parte Curtis | ||||||
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Supreme Court of the United States |
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Decided December 18, 1882 | ||||||
Full case name | Ex parte Curtis | |||||
Citations | 106 U.S. 371 (more) 1 S. Ct. 381; 27 L. Ed. 232; 16 Otto 371 |
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Prior history | From the Circuit Court for the Southern District of New York | |||||
Holding | ||||||
The sixth section of the act of August 15, 1876, is not unconstitutional | ||||||
Court membership | ||||||
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Case opinions | ||||||
Majority | Waite, C.J., joined by Miller, Field, Harlan, Woods, Matthews, Gray, Blatchford | |||||
Dissent | Bradley |
Ex parte Curtis, 106 U.S. 371 (1882), is an 8-to-1 ruling by the United States Supreme Court which held that the Act of August 15, 1876, was a constitutionally valid exercise of the enumerated powers of the United States Congress under Article One, Section 8 of the United States Constitution.
The petitioner had been convicted of receiving money for political purposes in violation of the Act of August 15, 1876. The petitioner then asked the Supreme Court for a writ of habeas corpus.
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Chief Justice Morrison Waite wrote the opinion for the majority. The constitutional grounds under which the petitioner challenged the Act were not discussed by the Court. Chief Justice Waite noted that Congress had a lengthy history of passing laws restricting the rights and privileges of civil servants, and that the constitutionality of such laws had never before been challenged.
Next, Waite affirmed that Article One, Section 8 of the Constitution clearly gave Congress the power to determine for itself what was proper in the realm of reining in political corruption:
Waite refused to pass judgment on the validity of the writ of habeas corpus, concluding that the Supreme Court's "jurisdiction is limited to the single question of the power of the court to commit the prisoner for the act of which he has been convicted."[2]
Associate Justice Joseph P. Bradley dissented. He concluded that the Act impermissibly infringed on the First Amendment rights of freedom of speech and freedom of association:
Justice Bradley also concluded that the Act was overbroad, and that the same positive ends (ending political corruption) could have been achieved by alternative, narrower means.[4]
One of the interesting aspects of the majority's decision is that it believed Congress did not prohibit civil servants from making political donations on their own, but rather prohibited making such donations through their supervisors.[5] But Justice Bradley dissented, in part, by arguing that the law banned even voluntary contributions made through superiors (a ban he felt was unconstitutional).[5]
At least one commentator has concluded that Ex parte Curtis is still "good law."[5]