Hayburn's Case
Encyclopedia
Hayburn's Case, 2 U.S. 409
(1792), was a case in which the Supreme Court of the United States
was invited to rule on whether certain non-judicial duties could be assigned by Congress
to the federal circuit courts in their official capacity. This was the first time that the Supreme Court addressed the issue of justiciability
. Congress eventually reassigned the duties in question, and the Supreme Court never gave judgment in this case.
to apply for pensions to the United States Circuit Courts. The decisions of the courts in such cases were subject to stay by the Secretary of War, pending further action by Congress. Three Circuit Courts balked, on the grounds that the Constitution insulated them from such non-judicial duties and preserved their decisions from correction by the political branches. They communicated their objections in remonstrances to the President, who shared them with Congress. In the following Term of the Supreme Court, United States Attorney General
Edmund Randolph
petitioned for a writ of mandamus
commanding the Circuit Court for the District of Pennsylvania to proceed in accordance with the Act. His original petition was made ex officio, but when the Supreme Court expressed doubts about proceeding in such fashion, he changed his position, averring that he was bringing the petition on behalf of William Hayburn, a pension applicant. At that point, the Supreme Court took the matter under advisement and bound the case over until its next term. While Hayburn’s petition was thus pending, Congress intervened with the Act of February 28, 1793, relieving the Circuit Courts of the duty of processing such pension applications.
appended a long footnote in which he quoted from the remonstrances. At the time of this case, each Justice of the Supreme Court served also on a Circuit Court. Thus, while the Supreme Court of the United States never ruled on the constitutionality of the Invalid Pensions Act of 1792, five of its six members, Jay
, Cushing
, Wilson
, Blair and Iredell
, declared it unconstitutional as members of the United States Circuit Courts for the Districts of New York, Pennsylvania and North Carolina.
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...
(1792), was a case in which the Supreme Court of the United States
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...
was invited to rule on whether certain non-judicial duties could be assigned by Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
to the federal circuit courts in their official capacity. This was the first time that the Supreme Court addressed the issue of justiciability
Justiciability
Justiciability concerns the limits upon legal issues over which a court can exercise its judicial authority. It includes, but is not limited to, the legal concept of standing, which is used to determine if the party bringing the suit is a party appropriate to establishing whether an actual...
. Congress eventually reassigned the duties in question, and the Supreme Court never gave judgment in this case.
Facts and procedural history
By the Invalid Pensions Act of 1792, Congress created a scheme for disabled veterans of the American RevolutionAmerican Revolution
The American Revolution was the political upheaval during the last half of the 18th century in which thirteen colonies in North America joined together to break free from the British Empire, combining to become the United States of America...
to apply for pensions to the United States Circuit Courts. The decisions of the courts in such cases were subject to stay by the Secretary of War, pending further action by Congress. Three Circuit Courts balked, on the grounds that the Constitution insulated them from such non-judicial duties and preserved their decisions from correction by the political branches. They communicated their objections in remonstrances to the President, who shared them with Congress. In the following Term of the Supreme Court, United States Attorney General
United States Attorney General
The United States Attorney General is the head of the United States Department of Justice concerned with legal affairs and is the chief law enforcement officer of the United States government. The attorney general is considered to be the chief lawyer of the U.S. government...
Edmund Randolph
Edmund Randolph
Edmund Jennings Randolph was an American attorney, the seventh Governor of Virginia, the second Secretary of State, and the first United States Attorney General.-Biography:...
petitioned for a writ of mandamus
Mandamus
A writ of mandamus or mandamus , or sometimes mandate, is the name of one of the prerogative writs in the common law, and is "issued by a superior court to compel a lower court or a government officer to perform mandatory or purely ministerial duties correctly".Mandamus is a judicial remedy which...
commanding the Circuit Court for the District of Pennsylvania to proceed in accordance with the Act. His original petition was made ex officio, but when the Supreme Court expressed doubts about proceeding in such fashion, he changed his position, averring that he was bringing the petition on behalf of William Hayburn, a pension applicant. At that point, the Supreme Court took the matter under advisement and bound the case over until its next term. While Hayburn’s petition was thus pending, Congress intervened with the Act of February 28, 1793, relieving the Circuit Courts of the duty of processing such pension applications.
Decision
The only decision by the Supreme Court in this case was to continue it. None was ever handed down on the constitutional questions it presented. In his report of the hearing and continuance, DallasAlexander J. Dallas (statesman)
Alexander James Dallas was an American statesman who served as the U.S. Treasury Secretary under President James Madison....
appended a long footnote in which he quoted from the remonstrances. At the time of this case, each Justice of the Supreme Court served also on a Circuit Court. Thus, while the Supreme Court of the United States never ruled on the constitutionality of the Invalid Pensions Act of 1792, five of its six members, Jay
John Jay
John Jay was an American politician, statesman, revolutionary, diplomat, a Founding Father of the United States, and the first Chief Justice of the United States ....
, 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...
, Wilson
James Wilson
James Wilson was one of the Founding Fathers of the United States and a signer of the United States Declaration of Independence. Wilson was elected twice to the Continental Congress, and was a major force in drafting the United States Constitution...
, Blair and 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...
, declared it unconstitutional as members of the United States Circuit Courts for the Districts of New York, Pennsylvania and North Carolina.