''Hayburn's Case'', 2 U.S. (2 Dall.) 409 (1792), was a case in which the
Supreme Court of the United States was invited to rule on whether certain non-judicial duties could be assigned by
Congress
A congress is a formal meeting of the representatives of different countries, constituent states, organizations, trade unions, political parties, or other groups. The term originated in Late Middle English to denote an encounter (meeting of ...
to the federal circuit courts in their official capacity. This was the first time that the Supreme Court addressed the issue of
justiciability
Justiciability concerns the limits upon legal issues over which a court can exercise its judicial authority. It includes, but is not limited to, the legal concept of standing, which is used to determine if the party bringing the suit is a party ...
. Congress eventually reassigned the duties in question, and the Supreme Court never gave judgment in this case.
Facts and procedural history
By the Invalid Pensions Act of 1792, Congress created a scheme for disabled veterans of the
American Revolution
The American Revolution was an ideological and political revolution that occurred in British America between 1765 and 1791. The Americans in the Thirteen Colonies formed independent states that defeated the British in the American Revoluti ...
to apply for pensions to the
United States Circuit Courts
The United States circuit courts were the original intermediate level courts of the United States federal court system. They were established by the Judiciary Act of 1789. They had trial court jurisdiction over civil suits of diversity jurisdict ...
. The decisions of the courts in such cases were subject to stay by the
Secretary of War
The secretary of war was a member of the U.S. president's Cabinet, beginning with George Washington's administration. A similar position, called either "Secretary at War" or "Secretary of War", had been appointed to serve the Congress of the ...
, pending further action by Congress. Three Circuit Courts balked, on the grounds that the Constitution insulated them from such non-judicial duties and preserved their decisions from correction by the political branches. They communicated their objections in remonstrances to the
President
President most commonly refers to:
*President (corporate title)
* President (education), a leader of a college or university
* President (government title)
President may also refer to:
Automobiles
* Nissan President, a 1966–2010 Japanese ...
, who shared them with Congress. In the following Term of the Supreme Court,
United States Attorney General
The United States attorney general (AG) is the head of the United States Department of Justice, and is the chief law enforcement officer of the federal government of the United States. The attorney general serves as the principal advisor to the p ...
Edmund Randolph
Edmund Jennings Randolph (August 10, 1753 September 12, 1813) was a Founding Father of the United States, attorney, and the 7th Governor of Virginia. As a delegate from Virginia, he attended the Constitutional Convention and helped to create ...
petitioned for a writ of
mandamus commanding the Circuit Court for the District of Pennsylvania to proceed in accordance with the Act. His original petition was made ex officio, but when the Supreme Court expressed doubts about proceeding in such fashion, he changed his position, averring that he was bringing the petition on behalf of William Hayburn, a pension applicant. At that point, the Supreme Court took the matter under advisement and bound the case over until its next term. While Hayburn's petition was thus pending, Congress intervened with the Act of February 28, 1793, relieving the Circuit Courts of the duty of processing such pension applications.
Decision
The only decision by the Supreme Court in this case was to continue it. None was ever handed down on the constitutional questions it presented. In his report of the hearing and continuance,
Dallas
Dallas () is the List of municipalities in Texas, third largest city in Texas and the largest city in the Dallas–Fort Worth metroplex, the List of metropolitan statistical areas, fourth-largest metropolitan area in the United States at 7.5 ...
appended a long footnote in which he quoted from the remonstrances. At the time of this case, each Justice of the Supreme Court served also on a Circuit Court. Thus, while the Supreme Court of the United States never ruled on the constitutionality of the Invalid Pensions Act of 1792, five of its six members,
Jay
A jay is a member of a number of species of medium-sized, usually colorful and noisy, passerine birds in the Crow family, Corvidae. The evolutionary relationships between the jays and the magpies are rather complex. For example, the Eurasian m ...
,
Cushing,
Wilson,
Blair and
Iredell, declared it unconstitutional as members of the United States Circuit Courts for the Districts of New York, Pennsylvania and North Carolina.
The decision, however, may have been due to the lack of the authority of the appellant, the Attorney General of the United States, Edmund Randolph, to bring the appeal to the Supreme Court. Attorney General Randolph initiated the case at the Supreme Court neither on behalf of the United States or Mr. Hayburn. The Court declined to rule on a lower court decision, possibly because only the Attorney General wanted it to do so.
[See Marcus & Teir, "Hayburn's Case: A Misinterpretation of Precedent," 1988 Wis. L. Rev. 4; Bloch, "The Early Role of the Attorney General in Our Constitutional Scheme: In the Beginning There was Pragmatism," 1989 Duke L. J. 561, 590-618 - See more at: http://constitution.findlaw.com/article3/annotation03.html#sthash.7IjdO3cd.dpuf]
See also
*
List of United States Supreme Court cases, volume 2
References
External links
*
{{USArticleIII
United States Supreme Court cases
United States Constitution Article Three case law
1792 in United States case law
United States Supreme Court cases of the Jay Court
United States justiciability case law
Veterans' affairs law in the United States