Samuel Chase

Samuel Chase
Associate Justice of the United States Supreme Court
In office
January 27, 1796[1] – June 19, 1811
Nominated by George Washington
Preceded by John Blair
Succeeded by Gabriel Duvall
Personal details
Born April 17, 1741(1741-04-17)
Somerset County, Maryland
Died June 19, 1811(1811-06-19) (aged 70)
Baltimore, Maryland
Political party Federalist
Religion Episcopalian
Signature

Samuel Chase (17th April 1741 – June 19, 1811) was an Associate Justice of the United States Supreme Court and earlier was a signatory to the United States Declaration of Independence as a representative of Maryland. Early in life, Chase was a "firebrand" states-righter and revolutionary.[2] His political views changed over his lifetime and in the last decades of his career he became well-known as a staunch Federalist, and was impeached for allegedly letting his partisan leanings affect his court decisions. Chase was acquitted.

Contents

Youth and early career

Samuel was the only child of the Reverend Thomas Chase (c. 1703 – 1779) and his wife, Matilda Walker (?-by 1744), born near Princess Anne, Maryland.[3]

His father was a clergyman who immigrated to Somerset County to become a priest in a new church. Samuel was educated at home. He was eighteen when he left for Annapolis where he studied law under attorney John Hall.[3] He was admitted to the bar in 1761[4] and started a law practice in Annapolis. It was during his time as a member of the bar that his colleagues gave him the nickname of "Old Bacon Face."[5]

Family and personal life

In May 1762, Chase married Ann Baldwin, daughter of Thomas Baldwin and his wife Agnes. Samuel and Anne had had three sons and four daughters, with only four surviving to adulthood.[3] Anne died in 1776.

In 1784, Chase traveled to England to deal with Maryland's Bank of England stock, where he met Hannah Kilty, daughter of Samuel Giles, a Berkshire physician. They were married later that year and had two daughters. The couple begot daughter Hannah and daughter Elisa into the world.[6][3]

Career in Annapolis

In 1762, Chase was expelled from the Forensic Club, an Annapolis debating society, for "extremely irregular and indecent" behavior.[3] This was only the first of the major controversies to surround his life.

In 1764, Chase was elected to the Maryland General Assembly where he served for twenty years.[4]

In 1766, he became embroiled in a war of words with a number of loyalist members of the Maryland political establishment. In an open letter dated July 18, 1766 Chase attacked Walter Dulany, George Steuart (1700–1784), John Brice (1705–1766) and others for publishing an article in the Maryland Gazette Extraordinary of June 19, 1766, in which Chase was accused of being: "a busy, reckless incendiary, a ringleader of mobs, a foul-mouthed and inflaming son of discord and faction, a common disturber of the public tranquility". In his response, Chase accused Steuart and the others of "vanity...pride and arrogance", and of being brought to power by "proprietory influence, court favour, and the wealth and influence of the tools and favourites who infest this city." [7]

In 1769 he started construction of the mansion that would become known as the Chase-Lloyd House, which he sold unfinished in 1771. The house is now a National Historic Landmark.

He co-founded Anne Arundel County's Sons of Liberty chapter with his close friend William Paca as well as leading opposition to the 1765 Stamp Act.[3]

Continental Congress

From 1774 to 1776, Chase was a member of the Annapolis Convention. He represented Maryland at the Continental Congress, was re-elected in 1776 and signed the United States Declaration of Independence.[4]

He remained in the Continental Congress until 1778. The involvement of Chase in an attempt to corner the flour market, using insider information gained through his position in the Congress, resulted in his not being returned to the Continental Congress and damaging his reputation.

Judicial career

In 1786, Chase moved to Baltimore, which remained his home for the rest of his life. In 1788, he was appointed Chief justice of the District Criminal Court in Baltimore and served until 1796. In 1791, he became Chief Justice of the Maryland General Court, again serving until 1796.[4]

On January 26, 1796, President George Washington appointed Chase as an associate justice of the Supreme Court of the United States. Chase served on the Court until his death on June 19, 1811.[4]

Impeachment

President Thomas Jefferson, alarmed at the seizure of power by the judiciary through the claim of exclusive judicial review, led his party's efforts to remove the Federalists from the bench. His allies in Congress had shortly after his inauguration repealed the Judiciary Act of 1801, abolishing the lower courts created by the legislation and terminating their Federalist judges despite lifetime appointments; Chase, two years after the repeal in May 1803, had denounced it in his charge to a Baltimore grand jury, saying that it would "take away all security for property and personal liberty, and our Republican constitution will sink into a mobocracy[.]"[8] Jefferson saw the attack as indubitable bad behavior and an opportunity to reduce the Federalist influence on the judiciary by impeaching Chase, launching the process from the White House when he wrote to Congressman Joseph Hopper Nicholson of Maryland asking: "Ought the seditious and official attack [by Chase] on the principles of our Constitution . . .to go unpunished?"[9]

Virginia Congressman John Randolph of Roanoke took up the challenge and took charge of the impeachment. The House of Representatives served Chase with eight articles of impeachment in late 1804, one of which involved Chase's handling of the trial of John Fries. Two more focused on his conduct in the political libel trial of James Callender. Four articles focused on procedural errors made during Chase's adjudication of various matters, and an eighth was directed at his “intemperate and inflammatory … peculiarly indecent and unbecoming … highly unwarrantable … highly indecent” remarks while "charging" or authorizing a Baltimore grand jury. The Jeffersonian Republicans-controlled United States Senate began the impeachment trial of Chase in early 1805, with Vice President Aaron Burr presiding and Randolph leading the prosecution.

All the counts involved Chase's work as a trial judge in lower circuit courts. (In that era, Supreme Court justices had the added duty of serving as individuals on circuit courts, a practice that was ended in the late 19th century.) The heart of the allegations was that political bias had led Chase to treat defendants and their counsel in a blatantly unfair manner. Chase's defense lawyers called the prosecution a political effort by his Republican enemies. In answer to the articles of impeachment, Chase argued that all of his actions had been motivated by adherence to precedent, judicial duty to restrain advocates from improper statements of law, and considerations of judicial efficiency.

The Senate voted to acquit Chase of all charges on March 1, 1805. He is the only U.S. Supreme Court justice to have been impeached.[4]

The impeachment raised constitutional questions over the nature of the judiciary and was the end of a series of efforts to define the appropriate extent of judicial independence under the Constitution. It set the limits of the impeachment power, fixed the concept that the judiciary was prohibited from engaging in partisan politics, defined the role of the judge in a criminal jury trial, and clarified judicial independence. The construction was largely attitudinal as it modified political norms without codifying new legal doctrines.[10]

The acquittal of Chase — by lopsided margins on several counts — set an unofficial precedent that many historians say helped ensure the independence of the judiciary. As Chief Justice William Rehnquist noted in his book Grand Inquests, some senators declined to convict Chase despite their partisan hostility to him, apparently because they doubted that the mere quality of his judging was grounds for removal. Furthermore, federal judges became much more cautious by avoiding the appearance of political partisanship.[11] All impeachments of federal judges since Chase have been based on allegations of legal or ethical misconduct, not on judicial performance.

Death

Samuel Chase died of a heart attack in 1811 and was interred in St. Paul's Cemetery, which today is the name of a large, semi-rural cemetery southeast of the Baltimore Inner Harbor. However, in Chase's lifetime, "St. Paul's Cemetery" referred to a downtown churchyard on West Lombard Street. Notwithstanding, the cemetery entrance—open only on Saturday mornings—is on Redwood Street.[12][13][14]

References

  1. ^ "Federal Judicial Center: Samuel Chase". 2009-12-09. http://www.fjc.gov/servlet/tGetInfo?jid=415. Retrieved 2009-12-09. 
  2. ^ "Samuel Chase, Freedom Firebrand". Delmarva Heritage Series by Dr. William H. Wroten, Jr.. Salisbury Times. March 23, 1959. http://nabbhistory.salisbury.edu/resources/wroten/wroten_schase.html. Retrieved 2008-05-26. 
  3. ^ a b c d e f "Chase, Samuel (1741–1811)". Maryland Online Encyclopedia (MdOE). Maryland Online Encyclopedia, a joint project of the Maryland Historical Society, the Maryland Humanities Council, the Enoch Pratt Free Library, and the Maryland State Department of Education. 2005. http://www.mdoe.org/chasesamuel.html. Retrieved 2007-12-05. 
  4. ^ a b c d e f "Samuel Chase". The Supreme Court Historical Society. Archived from the original on 2007-07-13. http://web.archive.org/web/20070713052523/http://www.supremecourthistory.org/02_history/subs_timeline/images_associates/007.html. Retrieved 2007-12-05. 
  5. ^ "Marbury v. Madison: Nail-Biting Drama?". Legalities, ABC News Blog. http://blogs.abcnews.com/legalities/2009/02/marbury-v-madis.html. Retrieved 2009-08-27. 
  6. ^ http://colonialhall.com/chase/chaseAnn.php
  7. ^ Sanderson, John J, p.67, Biography of the Signers To the Declaration of Independence, Volume 5, published by R W Pomery (1823). Retrieved Jan 21 2010
  8. ^ Rehnquist, William H. Grand Inquests: The Historic Impeachments of Justice Samuel Chase and President Andrew Johnson. Quill: 1992, p.52
  9. ^ Jerry W. Knudson, "The Jeffersonian Assault on the Federalist Judiciary, 1802-1805: Political Forces and Press Reaction," American Journal of Legal History 1970 14(1): 55-75; Richard Ellis, "The Impeachment of Samuel Chase," in American Political Trials, ed. by Michael R. Belknap (1994) pp 57-76, quote on p. 64.
  10. ^ Keith E. Whittington, "Reconstructing the Federal Judiciary: The Chase Impeachment and the Constitution," Studies in American Political Development 1995 v9#1: 55-116.
  11. ^ Richard Lillich, "The Chase Impeachment," American Journal of Legal History 1960 4(1): 49-72.
  12. ^ Samuel Chase at Find a Grave
  13. ^ Christensen, George A. (1983) Here Lies the Supreme Court: Gravesites of the Justices, Yearbook Supreme Court Historical Society at Internet Archive.
  14. ^ See also, Christensen, George A., Here Lies the Supreme Court: Revisited, Journal of Supreme Court History, Volume 33 Issue 1, Pages 17 - 41 (19 Feb 2008), University of Alabama.

Further reading

  • Abraham, Henry J. (1992). Justices and Presidents: A Political History of Appointments to the Supreme Court (3rd ed.). New York: Oxford University Press. ISBN 0-19-506557-3. 
  • Cushman, Clare (2001). The Supreme Court Justices: Illustrated Biographies, 1789–1995 (2nd ed.). (Supreme Court Historical Society, Congressional Quarterly Books). ISBN 1568021267. 
  • Frank, John P. (1995). Friedman, Leon; Israel, Fred L.. eds. The Justices of the United States Supreme Court: Their Lives and Major Opinions. Chelsea House Publishers. ISBN 0791013774. 
  • Hall, Kermit L., ed (1992). The Oxford Companion to the Supreme Court of the United States. New York: Oxford University Press. ISBN 0195058356. 
  • Haw, James; F. F. Beirne, R. S. Jett (1980). Stormy Patriot: the Life of Samuel Chase. Baltimore: Maryland Historical Society. ISBN 0938420003. 
  • Martin, Fenton S.; Goehlert, Robert U. (1990). The U.S. Supreme Court: A Bibliography. Washington, D.C.: Congressional Quarterly Books. ISBN 0871875543. 
  • Papenfuse, Edward C (July 1, 1987). Biographical Dictionary of the Maryland Legislature. 2 Vol. Set. Baltimore: The Johns Hopkins University Press. ISBN 0801835704. 
  • The Impeachment of Justice Samuel Chase.
  • Urofsky, Melvin I. (1994). The Supreme Court Justices: A Biographical Dictionary. New York: Garland Publishing. pp. 590. ISBN 0815311761. 

External links

Legal offices
Preceded by
John Blair
Associate Justice of the Supreme Court of the United States
1796-1811
Succeeded by
Gabriel Duvall