Calder v. Bull
Encyclopedia
Calder v. Bull, 3 U.S. 386 (1798), is a United States Supreme Court case in which the Court examined its authority to review state legislature decisions.
, overruling an earlier court ruling. In a unanimous decision, the United States Supreme Court held that the legislature's actions did not violate the ex post facto law
in article 1, section 10 of the Constitution
, which states:
An ex post facto law
or retroactive law, is a law that retroactively changes the legal consequences of acts committed or the legal status of facts and relationships that existed prior to the enactment of the law.
The holding in this case still remains good law: the ex post facto provision of the Constitution applies solely to criminal cases, not civil cases.
, James Iredell
, William Paterson and Samuel Chase
.
Justice Samuel Chase
argued that the government has no authority to interfere with an individual's rights, and "the general principles of law and reason" forbid the legislature from interfering. He then explained that judges ought to rely on natural law
when making their decisions:
Justice James Iredell
stated that courts cannot strike down statutes based only upon principles of natural justice:
Iredell affirmed the ability of the Supreme Court to review legislative acts, but based on something more than principles of natural justice:
And:
Justice William Cushing
agreed with the judgement, saying that:
Background
The Connecticut legislature ordered a new trial in a court case about the contents of a willWill (law)
A will or testament is a legal declaration by which a person, the testator, names one or more persons to manage his/her estate and provides for the transfer of his/her property at death...
, overruling an earlier court ruling. In a unanimous decision, the United States Supreme Court held that the legislature's actions did not violate the ex post facto law
Ex post facto law
An ex post facto law or retroactive law is a law that retroactively changes the legal consequences of actions committed or relationships that existed prior to the enactment of the law...
in article 1, section 10 of the Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
, which states:
An ex post facto law
Ex post facto law
An ex post facto law or retroactive law is a law that retroactively changes the legal consequences of actions committed or relationships that existed prior to the enactment of the law...
or retroactive law, is a law that retroactively changes the legal consequences of acts committed or the legal status of facts and relationships that existed prior to the enactment of the law.
The holding in this case still remains good law: the ex post facto provision of the Constitution applies solely to criminal cases, not civil cases.
Legal arguments
In this case, the participating Supreme Court judges were: William CushingWilliam Cushing
William Cushing was an early Associate Justice of the United States Supreme Court, from its inception to his death. He was the longest-serving of the Court's original members, sitting on the bench for 21 years...
, James Iredell
James Iredell
James Iredell was one of the first Justices of the Supreme Court of the United States. He was appointed by President George Washington and served from 1790 until his death in 1799...
, William Paterson and 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...
.
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...
argued that the government has no authority to interfere with an individual's rights, and "the general principles of law and reason" forbid the legislature from interfering. He then explained that judges ought to rely on natural law
Natural law
Natural law, or the law of nature , is any system of law which is purportedly determined by nature, and thus universal. Classically, natural law refers to the use of reason to analyze human nature and deduce binding rules of moral behavior. Natural law is contrasted with the positive law Natural...
when making their decisions:
Justice James Iredell
James Iredell
James Iredell was one of the first Justices of the Supreme Court of the United States. He was appointed by President George Washington and served from 1790 until his death in 1799...
stated that courts cannot strike down statutes based only upon principles of natural justice:
Iredell affirmed the ability of the Supreme Court to review legislative acts, but based on something more than principles of natural justice:
And:
Justice William Cushing
William Cushing
William Cushing was an early Associate Justice of the United States Supreme Court, from its inception to his death. He was the longest-serving of the Court's original members, sitting on the bench for 21 years...
agreed with the judgement, saying that:
See also
- List of United States Supreme Court cases, volume 3
- Rule according to higher lawRule according to higher lawThe rule according to a higher law means that no written law may be enforced by the government unless it conforms with certain unwritten, universal principles of fairness, morality, and justice...