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Samuel Freeman Miller

Samuel Freeman Miller

Overview
Samuel Freeman Miller (April 5, 1816 – October 13, 1890), was an associate justice of the United States Supreme Court, 1862–1890.

Born in Richmond, Kentucky
Richmond, Kentucky
Richmond is a city in and the county seat of Madison County, Kentucky, United States. It is named after Richmond, Virginia, and is the home of Eastern Kentucky University. The population of Richmond, Kentucky was 32,895 in 2008 and is expected to be 35,000 by 2010...

, Miller was the son of a farmer. He received a medical degree in 1838 from Transylvania University
Transylvania University
Transylvania University is a private liberal arts college related by covenant to the Christian Church . The college is located on a 35 acre campus about 4 blocks north of downtown Lexington, Kentucky, and is currently ranked number 77 on US News & World Report's Best Liberal Arts Colleges...

, Lexington, Kentucky
Lexington, Kentucky
Lexington is the second-largest city in Kentucky and the 65th largest in the United States. Known as the "Thoroughbred City" and the "Horse Capital of the World", it is located in the heart of Kentucky's Bluegrass region...

. While practicing medicine for a decade, he studied the law on his own and was admitted to the bar in 1847. He was for emancipation
Abolitionism
Abolitionism was a movement to end the slave trade and emancipate slaves in western Europe and the Americas. The slave system aroused little protest until the 18th century, when rationalist thinkers of the Enlightenment criticized it for violating the rights of man, and Quaker and other evangelical...

 and supported the Whigs
Whig Party (United States)
The Whig Party was a political party of the United States during the era of Jacksonian democracy. Considered integral to the Second Party System and operating from 1833 to 1856, the party was formed in opposition to the policies of President Andrew Jackson and the Democratic Party...

 in Kentucky
Kentucky
The Commonwealth of Kentucky is a state located in the East Central United States of America. Kentucky is a Southern state situated in the Upland South, although the state is infrequently placed, geographically and culturally, in the Midwest. Kentucky is one of four U.S. states constituted as a...

 before moving to Keokuk, Iowa
Keokuk, Iowa
Keokuk is a city in the southeastern part of the U.S. state of Iowa and one of the county seats of Lee County. The other county seat is Fort Madison. The population was 11,427 at the 2000 census. The city is named after Sauk Chief Keokuk, who is buried in Rand Park. It is located in the extreme...

, a state more amenable to his views on slavery.
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Encyclopedia
Samuel Freeman Miller (April 5, 1816 – October 13, 1890), was an associate justice of the United States Supreme Court, 1862–1890.

Born in Richmond, Kentucky
Richmond, Kentucky
Richmond is a city in and the county seat of Madison County, Kentucky, United States. It is named after Richmond, Virginia, and is the home of Eastern Kentucky University. The population of Richmond, Kentucky was 32,895 in 2008 and is expected to be 35,000 by 2010...

, Miller was the son of a farmer. He received a medical degree in 1838 from Transylvania University
Transylvania University
Transylvania University is a private liberal arts college related by covenant to the Christian Church . The college is located on a 35 acre campus about 4 blocks north of downtown Lexington, Kentucky, and is currently ranked number 77 on US News & World Report's Best Liberal Arts Colleges...

, Lexington, Kentucky
Lexington, Kentucky
Lexington is the second-largest city in Kentucky and the 65th largest in the United States. Known as the "Thoroughbred City" and the "Horse Capital of the World", it is located in the heart of Kentucky's Bluegrass region...

. While practicing medicine for a decade, he studied the law on his own and was admitted to the bar in 1847. He was for emancipation
Abolitionism
Abolitionism was a movement to end the slave trade and emancipate slaves in western Europe and the Americas. The slave system aroused little protest until the 18th century, when rationalist thinkers of the Enlightenment criticized it for violating the rights of man, and Quaker and other evangelical...

 and supported the Whigs
Whig Party (United States)
The Whig Party was a political party of the United States during the era of Jacksonian democracy. Considered integral to the Second Party System and operating from 1833 to 1856, the party was formed in opposition to the policies of President Andrew Jackson and the Democratic Party...

 in Kentucky
Kentucky
The Commonwealth of Kentucky is a state located in the East Central United States of America. Kentucky is a Southern state situated in the Upland South, although the state is infrequently placed, geographically and culturally, in the Midwest. Kentucky is one of four U.S. states constituted as a...

 before moving to Keokuk, Iowa
Keokuk, Iowa
Keokuk is a city in the southeastern part of the U.S. state of Iowa and one of the county seats of Lee County. The other county seat is Fort Madison. The population was 11,427 at the 2000 census. The city is named after Sauk Chief Keokuk, who is buried in Rand Park. It is located in the extreme...

, a state more amenable to his views on slavery. Active in Hawkeye politics, he supported Abraham Lincoln
Abraham Lincoln
Abraham Lincoln was the 16th President of the United States, serving from March 1861 until his assassination in April 1865. He successfully led his country through its greatest internal crisis, the American Civil War, preserving the Union and ending slavery...

 in the 1860 election. Lincoln appointed Miller to the Supreme Court in 1862.

His opinions strongly favored Lincoln's positions, upholding his suspension of habeas corpus
Habeas corpus
Habeas corpus is a legal action, or writ, through which a person can seek relief from the unlawful detention of him or herself, or of another person. It protects the individual from harming him or herself, or from being harmed by the judicial system...

 and trials by military commission. After the war, his narrow reading of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution, along with the Thirteenth and Fifteenth Amendments, was adopted after the Civil War as one of the Reconstruction Amendments. It was adopted on July 9, 1868....

--he wrote the opinion in the Slaughterhouse Cases
Slaughterhouse Cases
The Slaughter-House Cases, was the first United States Supreme Court interpretation of the relatively new Fourteenth Amendment to the Constitution...

-- limited the effectiveness of the amendment. He later joined the majority opinions in United States v. Cruikshank
United States v. Cruikshank
United States v. Cruikshank, 92 U.S. 542 was an important United States Supreme Court decision in United States constitutional law, one of the earliest to deal with the application of the Bill of Rights to state governments following the adoption of the Fourteenth Amendment.-Background:On Easter...

and the Civil Rights Cases
Civil Rights Cases
The Civil Rights Cases, 109 U.S. 3 , were a group of five similar cases consolidated into one issue for the United States Supreme Court to review...

holding that the amendment did not give the United States government the power to stop private, as opposed to state-sponsored, discrimination against blacks. In Ex Parte Yarbrough,110 U.S. 651(1884), however, Miller held that the federal government had broad authority to act to protect black voters from violence by the Ku Klux Klan
Ku Klux Klan
Ku Klux Klan , informally known as The Klan, is the name of several past and present hate group organizations in the United States whose avowed purpose was to protect the rights of and further the interests of white Americans by violence and intimidation. The first such organizations originated in...

 and other private groups. Miller also supported the use of broad federal power under the commerce clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress has the power to regulate commerce with foreign nations, among the states, and with the Native American tribes...

 to trump state regulations, as in Wabash v. Illinois.

After the 1876 presidential election between Rutherford Hayes and Samuel Tilden, Miller served on the electoral commission that awarded the disputed electoral votes to Hayes. Ulysses Grant considered Miller for the chief justice post, but instead chose Morrison Waite
Morrison Waite
Morrison Remick Waite, nicknamed "Mott" was the Chief Justice of the United States from 1874 to 1888.-Early life and education:...

. In the 1880s, his name was floated as a Republican candidate for president.

Miller, a religious liberal, belonged to the Unitarian
Unitarianism
Unitarianism as a theology is the belief in the single personality of God, in contrast to the doctrine of the Trinity ....

 Church and served as President of the Unitarian's National Conference in 1884.

He died while still a member of the court, in Washington, D.C.
Washington, D.C.
Washington, D.C. , formally the District of Columbia and commonly referred to as Washington, the District, or simply D.C., is the capital of the United States, founded on July 16, 1790...

, and is buried in the Oakland Cemetery in Keokuk, Iowa
Keokuk, Iowa
Keokuk is a city in the southeastern part of the U.S. state of Iowa and one of the county seats of Lee County. The other county seat is Fort Madison. The population was 11,427 at the 2000 census. The city is named after Sauk Chief Keokuk, who is buried in Rand Park. It is located in the extreme...

.

Noteworthy Opinions Authored

  • The Slaughter-House Cases, 83 U.S. 36 (1873)
  • Murdock v. Memphis, 87 U.S. 20 Wall. 590 590 (1874)
  • In re Burrus, 136 U.S. 586 (1890)

Further reading

  • Ross, Michael A. 2003. Justice of Shattered Dreams: Samuel Freeman Miller and the Supreme Court during the Civil War Era. Louisiana State University Press.
  • --------, 1998, "Justice Miller's Reconstruction: The Slaughter-House Cases, Health Codes, and Civil Rights in New Orleans, 1861-1873," Journal of Southern History LXIV(4): 649-76.