Lyon's Case

Circuit Court
1 Stat. 596 (1798)

ELI5:

Rule of Law:

In a criminal prosecution under a federal statute, a jury is not competent to rule on the constitutionality of that statute; its role is confined to determining the facts and applying the law as instructed by the court.

Facts:

Matthew Lyon, a sitting member of the U.S. House of Representatives from Vermont, was a vocal political opponent of President John Adams's administration.
Lyon wrote a letter criticizing President Adams for his "unbounded thirst for ridiculous pomp, foolish adulation, and selfish avarice."
He also assisted in the publication of another letter, known as the Barlow letter, which was critical of the U.S. government's relations with France.
Lyon's writings were published in the Vermont Journal after Congress passed the Sedition Act of 1798.
The Sedition Act criminalized publishing "false, scandalous, and malicious writing" against the government, Congress, or the President with the intent to defame them or bring them into disrepute.

Procedural Posture:

A federal grand jury indicted Matthew Lyon in the United States Circuit Court for the District of Vermont for violating the Sedition Act of 1798.
Lyon was arrested and brought to trial before the court.
At trial, Lyon argued that the Sedition Act was unconstitutional, but this plea to the jurisdiction of the court was overruled.
The case proceeded to a trial by jury, where Justice Paterson presided and delivered the charge to the jury.

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Issue:

Does a jury have the authority to determine the constitutionality of the Sedition Act of 1798 in a criminal prosecution brought under that act?

Opinions:

Majority - Paterson, Circuit Justice

No. A jury does not have the authority to determine the constitutionality of a law passed by Congress. Justice Paterson instructed the jury that its role was strictly limited to factual determinations and that it had "nothing whatever to do with the constitutionality or unconstitutionality of the sedition law." He reasoned that Congress enacted the statute, and until it is declared void by a "tribunal competent for the purpose," its validity cannot be disputed by a jury. To allow every jury to pass on the constitutionality of a statute would lead to "great abuses." The jury's sole task was to determine two questions: 1) whether Mr. Lyon published the writings, and 2) whether he did so seditiously, meaning with the intent to make the President and government "odious or contemptible."

Analysis:

This case represents a historically significant application of the controversial Sedition Act of 1798 and an important early statement on judicial and jury roles. It firmly establishes the principle that the constitutionality of a statute is a question of law for the court, not a question of fact for the jury, a concept foundational to the doctrine of judicial review later solidified in Marbury v. Madison. The prosecution of a sitting congressman for political speech inflamed partisan tensions and contributed to the public backlash that led to the Sedition Act's expiration and the defeat of the Federalist party. While the legal ruling on the jury's role has endured, the underlying prosecution is now widely viewed as an unconstitutional suppression of political dissent under the First Amendment.

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