Cases - 1889 term

In re Neagle

Tue, 04 Mar 1890 13:00:00 +0000

Location

Restaurant in Train Station Lathrop, CA

United States

37° 49' 21.738" N, 121° 16' 35.796" W

See map: Google Maps

Case Basics

Docket No.

1472

Petitioner

In re Neagle

Petitioner Type

Petitioner

Respondent Type

Respondent

Heard By

Fuller Court (1890)

Decided By

Fuller Court (1890)

Opinion

135 U.S. 1 (1890)

Argued

Tuesday, March 4, 1890

Decided

Monday, April 14, 1890

Facts of the Case

Suspecting a plot against Justice Stephen J. Field's life, the U.S. Attorney General appointed Neagle, a U.S. Marshall, to protect him. Acting as Field's bodyguard, Neagle shot and killed a man who appeared about to attack the justice. After California officials arrested and jailed Neagle, the U.S. sought his release by a writ of habeas corpus.

Question

Was the state obligated to obey the writ even though no national statute empowered the Attorney General to provide judges with bodyguards?

Conclusion

Yes. The Court held that the Attorney General acted appropriately since assigning Neagle as Field's bodyguard assured that the nation's laws would be faithfully executed. Furthermore, Neagle's actions were consistent with a congressional statute which provided U.S. Marshalls with "the same powers, in executing the laws" as state sheriffs and deputies (who would have been allowed to deter an attack on Field's life).

Chicago, Minn. & St. Paul Ry. Co. v. Minnesota

Mon, 13 Jan 1890 13:00:00 +0000

Case Basics

Docket No.

762

Petitioner

Chicago, Minn. & St. Paul Ry. Co.

Petitioner Type

Petitioner

Respondent

Minnesota

Respondent Type

Respondent

Heard By

Fuller Court (1890)

Decided By

Fuller Court (1890)

Opinion

134 U.S. 418 (1890)

Argued

Monday, January 13, 1890

Decided

Monday, March 24, 1890

Facts of the Case

A Minnesota law made its railroad commission the final judge of the reasonableness of railroad rates. The railroad maintained that "it is always a judicial question as to whether a statute is repugnant to provisions of the constitution."

Question

Does the Minnesota law violate the due process clause of the 14th Amendment?

Conclusion

Yes. The statute did not provide procedural due process: railroads received no hearing or other chance to defend their rates before the commission. Moreover, a rate's reasonableness "is eminently a question for judicial investigation, requiring due process of law for its determination." A company denied the authority to charge a reasonable rate and unable to turn to a judicial mechanism for review would be deprived of the "lawful use of its property, and, thus, in substance, and effect, of the property without due process of law."

Davis v. Beason

jgoldman — Mon, 09 Dec 1889 13:00:00 +0000

Location

Samaria Village Election Precinct Samaria, ID

United States

42° 7' 4.0008" N, 112° 20' 9.9996" W

See map: Google Maps

Case Basics

Docket No.

1261

Appellant

Samuel D. Davis

Petitioner Type

Appellant

Respondent

Beason

Respondent Type

Respondent

Heard By

Fuller Court (1889-1890)

Decided By

Fuller Court (1889-1890)

Opinion

133 U.S. 333 (1890)

Argued

December 9-10, 1889

Decided

Monday, February 3, 1890

Advocates

F. S. Richards (argued the cause for the appellant)

S. Shellabarger (argued the cause for the appellant)

J. M. Wilson (argued the cause for the appellant)

H. W. Smith (argued the cause for the appellee)

Facts of the Case

An Idaho Territory statute required voters swear an oath stating that they were neither a polygamist nor were they a member of any organization that promoted polygamy. In April 1889, Samuel D. Davis, a member of the Church of Jesus Christ of Latter-Day Saints, whose members often practiced and advocated polygamy, was indicted for falsely swearing the oath prior to the 1888 election. Davis was convicted and sentenced to pay of fine of $500 and serve 250 days in county jail. On the same day as his conviction, Davis obtained a writ of habeas corpus, accusing the county sheriff of imprisoning him illegally. Davis claimed that requiring the oath violated his right to free exercise of religion under the First Amendment. The federal territorial court denied Davis' claim.

Question

Did requiring Davis swear an oath that he was not a member of an organization that promoted polygamy violate Davis' rights under the Free Exercise Clause of the First Amendment?

Conclusion

No. In a unanimous decision authored by Justice Stephen J. Field, the Court rejected the notion that polygamy was a meaningful tenet of a religion, and thus rejected Davis' claim to First Amendment protections. In his opinion, Justice Field condemned the practices of polygamy and bigamy, saying, "To extend exemption from punishment for such crimes would be to shock the moral judgment of the community. To call their advocacy a tenet of religion is to offend the common sense of mankind." The opinion goes on to note that "religion," in the context of the First Amendment, refers primarily to "one's views of his relations to his Creator" and "modes of worship" and is not intended to be "invoked as a protection against legislation for the punishment of acts inimical to the peace, good order, and morals of society."