Hart v. United States
1886 U.S. LEXIS 1902, 6 S. Ct. 961, 118 U.S. 62 (1886)
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Rule of Law:
Congress's exclusive constitutional power to make appropriations from the Treasury allows it to prohibit the payment of specific claims against the government, and this authority is not overridden by a presidential pardon granted to the claimant.
Facts:
- Before April 13, 1861, Simeon Hart delivered supplies, including flour, corn, and forage, to the United States, which created a financial claim against the government.
- In April 1861, at the start of the Civil War, Hart joined the insurgency against the United States.
- Hart actively supported the rebellion by furnishing the insurgents with supplies, money, and means of transportation.
- On November 3, 1865, after the war ended, the President of the United States granted Hart a full pardon and amnesty for all offenses arising from his participation in the rebellion.
- Hart, and later his estate, sought payment from the United States for the supplies he had delivered before the war.
Procedural Posture:
- The Secretary of War transmitted Simeon Hart's claim to the Court of Claims, a court of first instance for claims against the government, in 1873.
- Hart's representative filed a petition in the Court of Claims seeking payment from the United States.
- After an initial hearing, the Court of Claims dismissed the petition in a judgment entered in June 1880.
- The court granted the claimant's motion for a new trial.
- After a rehearing, the Court of Claims again entered a judgment dismissing the petition in May 1881.
- The claimant, Hart's administrator, appealed the judgment of the Court of Claims to the Supreme Court of the United States.
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Issue:
Does a presidential pardon for participation in a rebellion override a congressional statute that explicitly prohibits payment of pre-war government claims to individuals who supported that rebellion?
Opinions:
Majority - Mr. Justice Blatchford
No. A presidential pardon does not override a specific congressional prohibition on paying a claim. The Constitution (Art. I, Sec. 9) grants Congress the exclusive power to appropriate money from the Treasury. The joint resolution in question was a valid exercise of this appropriations power, declaring that a specific class of claims should not be paid. A pardon relieves an individual from punishment for past offenses but does not create an affirmative right to receive money from the government when Congress has forbidden such a payment. This case is distinct from precedents like United States v. Klein because Congress is not dictating the legal effect of a pardon to the judiciary, but rather exercising its own constitutional authority over the public purse.
Analysis:
This decision firmly establishes the supremacy of Congress's "power of the purse" over the effects of a presidential pardon concerning government payments. It clarifies that while a pardon can restore civil rights and forgive criminal liability, it cannot compel the legislative branch to appropriate funds. This reinforces the separation of powers by setting a clear boundary: the President's clemency power does not extend to controlling Treasury disbursements, a function reserved exclusively for Congress.
