Ableman v. Booth
Encyclopedia
Ableman v. Booth, , is a case in which the Supreme Court of the United States
held that state courts cannot issue rulings that contradict the decisions of federal courts, overturning a decision by the Supreme Court of Wisconsin
.
For example, it is illegal for state officials to interfere with the work of U.S. Marshals acting under federal laws.
The Ableman decision emphasized the dual form of American government and the independence of state and federal courts from one another.
was arrested for violating the Fugitive Slave Act when he helped incite a mob to rescue a black fugitive in Wisconsin from US Marshal Stephen V. R. Ableman. Booth sought a writ of habeas corpus from a Wisconsin state judge. The Wisconsin judge granted the writ, ordering Booth released from federal custody. The US Marshal appealed to the state supreme court, which ruled the federal law unconstitutional and affirmed Booth's release. When Ableman turned to the federal courts, the Wisconsin Supreme Court refused to recognize the authority of the federal courts, again ordered Booth's release, and declared the Fugitive Slave Act of 1850 unconstitutional. The Wisconsin Supreme Court thereby attempted to annul the judgment of the federal court.
The Court stated that in adopting the Constitution, the people granted certain powers to the federal government: "it was felt by the statesmen who framed the Constitution and by the people who adopted it that it was necessary that many of the rights of sovereignty which the States then possessed should be ceded to the General Government, and that, in the sphere of action assigned to it, it should be supreme, and strong enough to execute its own laws by its own tribunals, without interruption from a State or from State authorities." This was accomplished by adoption of the Supremacy Clause
, which makes federal law the supreme law of the land: "this Constitution, and the laws of the United States which shall be passed in pursuance thereof, and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land, and the judges in every State shall be bound thereby, anything in the Constitution or laws of any State to the contrary notwithstanding."
The Court noted that the supremacy of federal law could be effective only if the federal government were given judicial power to enforce federal law. If the interpretation of the Constitution and federal statutes were left to the states, then "conflicting decisions would unavoidably take place. . . . The Constitution and laws and treaties of the United States, and the powers granted to the Federal Government, would soon receive different interpretations in different States, and the Government of the United States would soon become one thing in one State and another thing in another. It was essential, therefore, to its very existence as a Government that it should have the power of establishing courts of justice, altogether independent of State power, to carry into effect its own laws, and that a tribunal should be established in which all cases which might arise under the Constitution and laws and treaties of the United States, whether in a State court or a court of the United States, should be finally and conclusively decided." Accordingly, said the Court, the Constitution granted this judicial power to the federal government. The Constitution provides in Article III that the judicial power in all cases arising under the Constitution or laws of the United States rests in the federal courts, and that the Supreme Court has appellate jurisdiction in all such cases.
Therefore, the Court concluded that the Constitution gives the federal courts the final authority in matters involving interpretation of the Constitution and laws of the United States. Because the Constitution grants this power to the federal courts, the state courts do not have the power to review or interfere with the judgments of federal courts in matters arising under the Constitution or laws of the United States. The Court therefore found that the power of the State of Wisconsin "is limited and restricted by the Constitution of the United States." Wisconsin did not have the power to annul the judgment of the federal court or to hold the Fugitive Slave Act unconstitutional. Booth's conviction therefore was upheld.
Booth was ultimately pardoned for his offense by President James Buchanan
shortly before he left office in 1861.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that state courts cannot issue rulings that contradict the decisions of federal courts, overturning a decision by the Supreme Court of Wisconsin
Wisconsin Supreme Court
The Wisconsin Supreme Court is the highest appellate court in the state of Wisconsin. The Supreme Court has jurisdiction over original actions, appeals from lower courts, and regulation or administration of the practice of law in Wisconsin.-Location:...
.
For example, it is illegal for state officials to interfere with the work of U.S. Marshals acting under federal laws.
The Ableman decision emphasized the dual form of American government and the independence of state and federal courts from one another.
Background
In 1854, abolitionist editor Sherman BoothSherman Booth
Sherman Booth was an abolitionist, editor and politician in Wisconsin. Born in Davenport, New York, Booth moved to Wisconsin from New York, just days before Wisconsin was granted statehood. He was one of the only members of the Free Soil Party in the state at the time, and he was a staunch...
was arrested for violating the Fugitive Slave Act when he helped incite a mob to rescue a black fugitive in Wisconsin from US Marshal Stephen V. R. Ableman. Booth sought a writ of habeas corpus from a Wisconsin state judge. The Wisconsin judge granted the writ, ordering Booth released from federal custody. The US Marshal appealed to the state supreme court, which ruled the federal law unconstitutional and affirmed Booth's release. When Ableman turned to the federal courts, the Wisconsin Supreme Court refused to recognize the authority of the federal courts, again ordered Booth's release, and declared the Fugitive Slave Act of 1850 unconstitutional. The Wisconsin Supreme Court thereby attempted to annul the judgment of the federal court.
Decision
The case went to the U.S. Supreme Court. The Court, in a unanimous opinion written by Chief Justice Roger B. Taney, stated that the Wisconsin Supreme Court had effectively asserted the supremacy of state courts over federal courts in cases arising under the Constitution and laws of the United States. The Court noted that if the Wisconsin courts could annul the judgment of conviction by the federal district court in this case, then any state court could annul any conviction under federal law. The Court held that the states do not have that power.The Court stated that in adopting the Constitution, the people granted certain powers to the federal government: "it was felt by the statesmen who framed the Constitution and by the people who adopted it that it was necessary that many of the rights of sovereignty which the States then possessed should be ceded to the General Government, and that, in the sphere of action assigned to it, it should be supreme, and strong enough to execute its own laws by its own tribunals, without interruption from a State or from State authorities." This was accomplished by adoption of the Supremacy Clause
Supremacy Clause
Article VI, Clause 2 of the United States Constitution, known as the Supremacy Clause, establishes the U.S. Constitution, U.S. Treaties, and Federal Statutes as "the supreme law of the land." The text decrees these to be the highest form of law in the U.S...
, which makes federal law the supreme law of the land: "this Constitution, and the laws of the United States which shall be passed in pursuance thereof, and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land, and the judges in every State shall be bound thereby, anything in the Constitution or laws of any State to the contrary notwithstanding."
The Court noted that the supremacy of federal law could be effective only if the federal government were given judicial power to enforce federal law. If the interpretation of the Constitution and federal statutes were left to the states, then "conflicting decisions would unavoidably take place. . . . The Constitution and laws and treaties of the United States, and the powers granted to the Federal Government, would soon receive different interpretations in different States, and the Government of the United States would soon become one thing in one State and another thing in another. It was essential, therefore, to its very existence as a Government that it should have the power of establishing courts of justice, altogether independent of State power, to carry into effect its own laws, and that a tribunal should be established in which all cases which might arise under the Constitution and laws and treaties of the United States, whether in a State court or a court of the United States, should be finally and conclusively decided." Accordingly, said the Court, the Constitution granted this judicial power to the federal government. The Constitution provides in Article III that the judicial power in all cases arising under the Constitution or laws of the United States rests in the federal courts, and that the Supreme Court has appellate jurisdiction in all such cases.
Therefore, the Court concluded that the Constitution gives the federal courts the final authority in matters involving interpretation of the Constitution and laws of the United States. Because the Constitution grants this power to the federal courts, the state courts do not have the power to review or interfere with the judgments of federal courts in matters arising under the Constitution or laws of the United States. The Court therefore found that the power of the State of Wisconsin "is limited and restricted by the Constitution of the United States." Wisconsin did not have the power to annul the judgment of the federal court or to hold the Fugitive Slave Act unconstitutional. Booth's conviction therefore was upheld.
Booth was ultimately pardoned for his offense by President James Buchanan
James Buchanan
James Buchanan, Jr. was the 15th President of the United States . He is the only president from Pennsylvania, the only president who remained a lifelong bachelor and the last to be born in the 18th century....
shortly before he left office in 1861.
See also
- List of United States Supreme Court cases, volume 62
- Dred Scott v. SandfordDred Scott v. SandfordDred Scott v. Sandford, , also known as the Dred Scott Decision, was a ruling by the U.S. Supreme Court that people of African descent brought into the United States and held as slaves were not protected by the Constitution and could never be U.S...
,