Ableman v. Booth
62 U.S. 506, 16 L. Ed. 169, 21 How. 506 (1859)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under the Supremacy Clause of the U.S. Constitution, state courts lack the authority to issue writs of habeas corpus to interfere with federal court proceedings or to order the release of prisoners held in custody by a federal officer under the authority of a federal law.
Facts:
- Sherman M. Booth was charged before a U.S. commissioner in Wisconsin with aiding and abetting the escape of a fugitive slave, a violation of the federal Fugitive Slave Act of 1850.
- The U.S. commissioner found probable cause to believe Booth was guilty and held him for trial in the U.S. District Court for the District of Wisconsin.
- Booth was committed to the custody of Stephen V. R. Ableman, the U.S. Marshal for the district.
- While in federal custody, Booth applied to a single justice of the Supreme Court of Wisconsin for a writ of habeas corpus, alleging his imprisonment was illegal because the Fugitive Slave Act was unconstitutional.
- The Wisconsin justice granted the writ and ordered Marshal Ableman to release Booth.
- Subsequently, a federal grand jury indicted Booth for the same offense.
- Booth was tried, convicted, and sentenced to imprisonment by the U.S. District Court.
- The full Supreme Court of Wisconsin again issued a writ of habeas corpus and ordered Booth's release from federal custody, declaring his imprisonment by the federal court to be illegal.
Procedural Posture:
- Sherman M. Booth petitioned a justice of the Supreme Court of Wisconsin for a writ of habeas corpus to secure his release from the custody of U.S. Marshal Stephen Ableman.
- The state justice granted the writ and ordered Booth's release.
- Marshal Ableman sought review from the full Supreme Court of Wisconsin, which affirmed the justice's decision to release Booth.
- Ableman, the appellant, then appealed this first decision to the U.S. Supreme Court.
- Separately, Booth was indicted, tried, and convicted in the U.S. District Court for the District of Wisconsin and sentenced to imprisonment.
- Booth again petitioned the Supreme Court of Wisconsin for a writ of habeas corpus.
- The Supreme Court of Wisconsin again ordered Booth's release from federal custody.
- The United States, as appellant, appealed this second decision to the U.S. Supreme Court, which consolidated the two cases for review.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state court have the authority to issue a writ of habeas corpus and order the release of a prisoner held in federal custody for violating a federal law?
Opinions:
Majority - Mr. Chief Justice Taney
No. A state court does not have the authority to release a prisoner held under the authority of the United States. The U.S. Constitution establishes a system of dual sovereignty where the federal government is supreme within its sphere of action. The Supremacy Clause dictates that the Constitution and federal laws are the supreme law of the land, binding on state judges. To ensure this supremacy and the uniform interpretation of federal law, the Constitution vests judicial power in the federal courts, with the U.S. Supreme Court holding ultimate appellate jurisdiction over state court decisions involving federal questions. Therefore, once a state court is judicially informed that a person is in custody under the authority of the United States, it can proceed no further; it has no jurisdiction to interfere with the judgment of a U.S. court or the duties of a federal officer. Allowing state courts to nullify federal laws and judgments would lead to anarchy and undermine the federal government's ability to function and enforce its laws.
Analysis:
Ableman v. Booth is a landmark decision powerfully affirming the principle of federal judicial supremacy. It unequivocally establishes that state courts cannot obstruct federal proceedings or release federal prisoners, thereby preventing states from nullifying federal law. This ruling solidifies the hierarchical structure of the American judicial system, placing the U.S. Supreme Court as the final arbiter of federal law. While the case arose from the deeply divisive Fugitive Slave Act, its core holding on the relationship between state and federal courts transcends that context and remains a foundational principle of American federalism.
Unlock the full brief for Ableman v. Booth