Hayburn's Case
2 U.S. 409, 1 L. Ed. 436 (1792)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Congress cannot constitutionally assign non-judicial duties to Article III courts, nor can it vest the executive or legislative branches with the power to review or revise the final judgments of the courts.
Facts:
- In 1792, Congress passed the Invalid Pensions Act to provide pensions for Revolutionary War veterans.
- The Act required U.S. Circuit Courts to examine pension applicants, evaluate their eligibility, and determine the amount of their pension.
- Under the Act, the decisions of the Circuit Courts were not final.
- The courts' decisions were to be reported to the Secretary of War, who was empowered to withhold a veteran's name from the pension list if he suspected 'imposition or mistake'.
- The Secretary of War was then required to transmit the list of applicants and the courts' findings to Congress for final action, allowing Congress to revise the courts' determinations.
Procedural Posture:
- William Hayburn submitted a petition for a pension under the Invalid Pensions Act of 1792 to the Circuit Court for the District of Pennsylvania.
- The judges of the Circuit Court refused to hear the claim in their judicial capacity, asserting the Act was unconstitutional.
- The Circuit Courts for the Districts of New York and North Carolina also declined to execute the Act in their judicial capacity for similar reasons.
- Attorney General Edmund Randolph filed a motion for a writ of mandamus in the U.S. Supreme Court, seeking to compel the Pennsylvania Circuit Court to proceed with Hayburn's claim.
- The Supreme Court heard arguments on the motion but held the matter under advisement and never issued a final ruling.
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 an Act of Congress violate the constitutional separation of powers by assigning federal courts duties that are not judicial in nature and by making their decisions subject to review and revision by the Executive and Legislative branches?
Opinions:
Majority - The Court (summary of Circuit Court opinions)
Yes, although the Supreme Court did not issue a final ruling on the merits, the collective reasoning of the Circuit Courts established that such an act violates the separation of powers. The duties assigned by the Act were not judicial in nature because they did not result in a final judgment. The Constitution separates the government into legislative, executive, and judicial branches, and it is the duty of the judiciary to remain distinct and independent. Subjecting the 'judgments' of a court to review and revision by an officer of the executive branch (the Secretary at War) or by the legislature is radically inconsistent with the independence of the judicial power vested in the courts by the Constitution.
Analysis:
Hayburn's Case is a foundational decision establishing the principles of judicial independence and the separation of powers. Although the Supreme Court never issued a final opinion on the merits, the uniform refusal of the circuit courts to execute the statute sent a clear message to Congress that the judiciary would not perform non-judicial functions or act as an advisory body to the other branches. This case set an early and critical precedent against legislative or executive encroachment on the judicial function, laying the groundwork for the doctrine of judicial review later articulated in Marbury v. Madison. It affirmed that the judgments of Article III courts must be final and not subject to revision by other branches.
Unlock the full brief for Hayburn's Case