Ahrens v. Clark
Encyclopedia
Ahrens v. Clark, was a United States Supreme Court case that denied a federal district court jurisdiction to issue a writ of habeas corpus if the person detained is not within the territorial jurisdiction of the court when the petition is filed. The 6-3 ruling was handed down on June 21, 1948, with the majority opinion written by Justice William O. Douglas
and the dissent written by Justice Wiley Blount Rutledge
.
The decision was substantially overturned in Braden v. 30th Judicial Circuit Court of Ky., which held that territorial jurisdiction is derived from the location of those responsible for the indictment rather than the location of the detainment itself.
for a writ of habeas corpus to challenge their detention and imminent deportation in court. The deportation order had been issued by Attorney General Tom C. Clark
utilizing wartime powers granted by President Harry Truman in the waning months of World War II. The detainees argued the D.C. court had jurisdiction because they were being held "subject to the custody and control" of the Attorney General. The government argued their case should be dismissed because Ellis Island is outside the territorial confines of the District of Columbia. The Supreme Court, the federal appeals courts, and the federal district courts had the power to grant writs of habeas corpus "within their respective jurisdictions"; the case hinged on whether the words "within their respective jurisdictions" implied a territorial limitation. The court held that they did.
outside the territorial jurisdiction of all federal district courts. One of the justices in those cases, John Paul Stevens
, had clerked for Justice Rutledge during the term Ahrens v. Clark was decided and helped draft Justice Rutledge's dissenting opinion. Justice Stevens would use his background from the case when drafting the majority opinion in Rasul v. Bush
.
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
and the dissent written by Justice Wiley Blount Rutledge
Wiley Blount Rutledge
Wiley Blount Rutledge, Jr. was an American educator, lawyer, and justice of the Supreme Court of the United States.-Early life:...
.
The decision was substantially overturned in Braden v. 30th Judicial Circuit Court of Ky., which held that territorial jurisdiction is derived from the location of those responsible for the indictment rather than the location of the detainment itself.
Overview
The D.C. District Court had been petitioned by 120 German detainees being held on Ellis IslandEllis Island
Ellis Island in New York Harbor was the gateway for millions of immigrants to the United States. It was the nation's busiest immigrant inspection station from 1892 until 1954. The island was greatly expanded with landfill between 1892 and 1934. Before that, the much smaller original island was the...
for a writ of habeas corpus to challenge their detention and imminent deportation in court. The deportation order had been issued by Attorney General Tom C. Clark
Tom C. Clark
Thomas Campbell Clark was United States Attorney General from 1945 to 1949 and an Associate Justice of the Supreme Court of the United States .- Early life and career :...
utilizing wartime powers granted by President Harry Truman in the waning months of World War II. The detainees argued the D.C. court had jurisdiction because they were being held "subject to the custody and control" of the Attorney General. The government argued their case should be dismissed because Ellis Island is outside the territorial confines of the District of Columbia. The Supreme Court, the federal appeals courts, and the federal district courts had the power to grant writs of habeas corpus "within their respective jurisdictions"; the case hinged on whether the words "within their respective jurisdictions" implied a territorial limitation. The court held that they did.
Significance
The case is significant because the question of territorial jurisdiction would again arise during the U.S. War on Terror, when the United States detained captives at a navy facility in Guantanamo BayGuantanamo Bay detainment camp
The Guantanamo Bay detention camp is a detainment and interrogation facility of the United States located within Guantanamo Bay Naval Base, Cuba. The facility was established in 2002 by the Bush Administration to hold detainees from the war in Afghanistan and later Iraq...
outside the territorial jurisdiction of all federal district courts. One of the justices in those cases, John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
, had clerked for Justice Rutledge during the term Ahrens v. Clark was decided and helped draft Justice Rutledge's dissenting opinion. Justice Stevens would use his background from the case when drafting the majority opinion in Rasul v. Bush
Rasul v. Bush
Rasul v. Bush, 542 U.S. 466 , is a landmark United States Supreme Court decision establishing that the U.S. court system has the authority to decide whether foreign nationals held in Guantanamo Bay were wrongfully imprisoned...
.
See also
- List of United States Supreme Court cases, volume 335
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Vinson Court
External links
- 335 U.S. 188 Full text of the opinion courtesy of Findlaw.com.