Stuart v. Laird
Encyclopedia
Stuart v. Laird, 5 U.S. 299
(1803), was a case decided by the John Marshall
-led U.S. Supreme Court, notably a week after the famous Marbury v. Madison
.
The case regards a circuit judge
's judgment, after the judge's job had been abolished by the repeal of the Judiciary Act of 1801. Stuart's lawyer was Charles Lee, who also represented William Marbury
. John Laird asked the Supreme Court to uphold the judge's ruling, while Stuart's team argued that (a) only the court that renders a judgment can enforce it and (b) the 1802 repeal of 1801's Judiciary Act was unconstitutional. Stuart lost on both accounts, and a dangerous show-down between the legislative and the judicial branches of the United States
' government was averted.
The case involved the Judiciary Act of 1801, which created a number of federal judgeships—the so-called "midnight judges
" as the Act was passed by the lame-duck
Federalists in their final days in office. The Act established new circuit court judges to hear intermediate appeals. As a result, Supreme Court justices would no longer have to "ride circuit" (which entailed substantial and often dangerous travel) to sit with district (trial) court judges to hear appeals throughout the nation. Yet soon after its passage, the statute was invalidated by the Repeal Act of March 8, 1802. Federalists attacked the Jeffersonian
legislation, arguing that federal judges were appointed for life and therefore could not be constitutionally removed by the Repeal Act. The Judiciary Act of 1802 reinstated circuit courts but also resurrected the practice of circuit riding. Many thought the new 1802 Act unconstitutional, including new Chief Justice John Marshall. Marshall argued that justices should not have to preside over circuit courts unless they were commissioned as circuit court judges. He wrote the other justices, "I am not of opinion that we can under our present appointments hold circuit courts, but I presume a contrary opinion is held by the Court and, if so, I shall conform to it." Justice Samuel Chase
agreed with Marshall, but the other justices did not.
With Marshall not participating (though very much active behind the scenes), Justice William Paterson held for a unanimous Court that Congress did have the authority under the Constitution both to establish and abolish lower federal courts.
Despite the Court sustaining the Judiciary Act of 1802, the issue of circuit riding was substantially lessened because the Act in effect made circuit riding optional: only one federal judge was required for a quorum on any circuit court. As a result, Supreme Court justices could rely on district court judges to hear intermediate appeals. This flexibility proved crucial to the demise of circuit riding. By the 1840s, the justices had all but stopped holding circuit courts.
Scholars such as Bruce Ackerman
have pointed to the Court's decision in Stuart v. Laird as part of the opposition Federalist Court's accommodation of the new Jeffersonian political regime.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1803), was a case decided by the John Marshall
John Marshall
John Marshall was the Chief Justice of the United States whose court opinions helped lay the basis for American constitutional law and made the Supreme Court of the United States a coequal branch of government along with the legislative and executive branches...
-led U.S. Supreme Court, notably a week after the famous Marbury v. Madison
Marbury v. Madison
Marbury v. Madison, is a landmark case in United States law and in the history of law worldwide. It formed the basis for the exercise of judicial review in the United States under Article III of the Constitution. It was also the first time in Western history a court invalidated a law by declaring...
.
The case regards a circuit judge
United States federal judge
In the United States, the title of federal judge usually means a judge appointed by the President of the United States and confirmed by the United States Senate in accordance with Article II of the United States Constitution....
's judgment, after the judge's job had been abolished by the repeal of the Judiciary Act of 1801. Stuart's lawyer was Charles Lee, who also represented William Marbury
William Marbury
William Marbury was one of the famous "Midnight Judges". Due to President John Adams's work in the night before he was to leave office, Marbury was to be appointed a Justice of the Peace in the District of Columbia. He was appointed there to give the Federalists a stronghold in the judicial...
. John Laird asked the Supreme Court to uphold the judge's ruling, while Stuart's team argued that (a) only the court that renders a judgment can enforce it and (b) the 1802 repeal of 1801's Judiciary Act was unconstitutional. Stuart lost on both accounts, and a dangerous show-down between the legislative and the judicial branches of the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
' government was averted.
The case involved the Judiciary Act of 1801, which created a number of federal judgeships—the so-called "midnight judges
Midnight Judges
The Midnight Judges Act represented an effort to solve an issue in the U.S. Supreme Court during the early 19th century. There was concern, beginning in 1789, about the system that required the justices of the Supreme Court to “ride circuit” and reiterate decisions made in the appellate level...
" as the Act was passed by the lame-duck
Lame duck (politics)
A lame duck is an elected official who is approaching the end of his or her tenure, and especially an official whose successor has already been elected.-Description:The status can be due to*having lost a re-election bid...
Federalists in their final days in office. The Act established new circuit court judges to hear intermediate appeals. As a result, Supreme Court justices would no longer have to "ride circuit" (which entailed substantial and often dangerous travel) to sit with district (trial) court judges to hear appeals throughout the nation. Yet soon after its passage, the statute was invalidated by the Repeal Act of March 8, 1802. Federalists attacked the Jeffersonian
Jeffersonian
Jeffersonian refers to several fields upon which the U.S. President Thomas Jefferson had an impact:*Jeffersonian architecture*Jeffersonian democracy*Jeffersonian Bible...
legislation, arguing that federal judges were appointed for life and therefore could not be constitutionally removed by the Repeal Act. The Judiciary Act of 1802 reinstated circuit courts but also resurrected the practice of circuit riding. Many thought the new 1802 Act unconstitutional, including new Chief Justice John Marshall. Marshall argued that justices should not have to preside over circuit courts unless they were commissioned as circuit court judges. He wrote the other justices, "I am not of opinion that we can under our present appointments hold circuit courts, but I presume a contrary opinion is held by the Court and, if so, I shall conform to it." Justice Samuel Chase
Samuel Chase
Samuel Chase 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...
agreed with Marshall, but the other justices did not.
With Marshall not participating (though very much active behind the scenes), Justice William Paterson held for a unanimous Court that Congress did have the authority under the Constitution both to establish and abolish lower federal courts.
Despite the Court sustaining the Judiciary Act of 1802, the issue of circuit riding was substantially lessened because the Act in effect made circuit riding optional: only one federal judge was required for a quorum on any circuit court. As a result, Supreme Court justices could rely on district court judges to hear intermediate appeals. This flexibility proved crucial to the demise of circuit riding. By the 1840s, the justices had all but stopped holding circuit courts.
Scholars such as Bruce Ackerman
Bruce Ackerman
Bruce Arnold Ackerman is an American constitutional law scholar. He is a Sterling Professor at Yale Law School and one of the most frequently cited legal academics in the United States....
have pointed to the Court's decision in Stuart v. Laird as part of the opposition Federalist Court's accommodation of the new Jeffersonian political regime.
External links
5 U.S. 299 Full text of the opinion courtesy of Findlaw.com.- http://www.michaelariens.com/ConLaw/cases/stuart.htm Written by a professor at St. Mary's University School of Law.
- http://press-pubs.uchicago.edu/founders/documents/a3_1s27.html
- http://www.law.missouri.edu/fisch/stuart.htm