Kendall v. United States Ex Rel. Stokes
12 Pet. 524, 9 L. Ed. 1181, 37 U.S. 524 (1838)
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Rule of Law:
A federal court with proper jurisdiction may issue a writ of mandamus to compel an executive officer to perform a purely ministerial act that an act of Congress has required, as such an order is not an unconstitutional interference with the executive's discretionary powers.
Facts:
- William B. Stokes and others had contracts with the Post Office Department to transport mail and claimed they were owed additional compensation for extra services.
- A previous Postmaster General had credited their accounts for these services, but the current Postmaster General, Amos Kendall, reversed these credits.
- In response to a memorial from Stokes, Congress passed a special act on July 2, 1836, for their relief.
- The act directed the Solicitor of the Treasury to investigate the claims and determine the equitable amount owed to Stokes.
- The act further directed the Postmaster General to credit Stokes's account with whatever sum the Solicitor awarded.
- The Solicitor investigated and awarded Stokes $161,563.89.
- Postmaster General Kendall credited only $122,102.46 of the award, refusing to credit the remaining balance of $39,462.43.
Procedural Posture:
- William B. Stokes and others filed a petition in the Circuit Court of the United States for the District of Columbia.
- The petition sought a writ of mandamus to command Postmaster General Amos Kendall to credit their accounts with the full amount awarded by the Solicitor of the Treasury.
- The Circuit Court granted the petition and ordered a peremptory mandamus against Kendall.
- Kendall, the Postmaster General, brought the case to the United States Supreme Court on a writ of error.
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Issue:
Does the Circuit Court of the United States for the District of Columbia have jurisdiction to issue a writ of mandamus compelling the Postmaster General to perform a ministerial duty mandated by an act of Congress?
Opinions:
Majority - Justice Thompson
Yes. The Circuit Court for the District of Columbia has the authority to issue a writ of mandamus to compel an executive officer to perform a specific, non-discretionary duty. The act required of the Postmaster General was a purely ministerial one, as the law gave him no discretion and positively commanded him to credit the full amount awarded by the Solicitor of the Treasury. This does not interfere with any executive function, but rather enforces a legal duty. The President’s constitutional obligation to 'take care that the laws be faithfully executed' does not imply a power to forbid their execution. While prior cases like M'Cluny v. Silliman held that federal circuit courts in the states lack this power, that was because Congress had not granted them the full judicial power authorized by the Constitution. In contrast, the act organizing the D.C. courts conferred broader jurisdiction, including all common law powers inherited from Maryland and cognizance of 'all cases in law and equity,' thus vesting the court with the authority to issue the writ in this instance.
Dissenting - Chief Justice Taney
No. The Circuit Court for the District of Columbia does not have the authority to issue a writ of mandamus to an officer of the general government. While the duty of the Postmaster General was ministerial, the court lacked jurisdiction to compel its performance. Previous Supreme Court decisions firmly established that circuit courts in the states do not possess this power, and there is no sound policy reason to grant greater power to the D.C. court. The adoption of Maryland common law does not confer this authority, as the power to issue such a prerogative writ was vested only in Maryland's highest court of general jurisdiction, not a local court. The statutory grant of jurisdiction over 'all cases in law and equity' is functionally equivalent to the language used for other circuit courts and does not create a special power. Congress did not explicitly grant this authority, and it should not be inferred from ambiguous language.
Analysis:
This decision solidifies the distinction between ministerial and discretionary executive acts, establishing a crucial judicial check on the executive branch. It affirms that when Congress imposes a specific, non-discretionary duty upon an executive officer, federal courts have the power to enforce compliance, ensuring that officials are not above the law. The case is also significant for establishing the unique and broader jurisdictional authority of the courts in the District of Columbia, which, unlike other federal courts at the time, were held to possess the full judicial power authorized by the Constitution, including common law remedies like mandamus against federal officials.
