Runkle v. United States
122 U.S. 543, 7 S. Ct. 1141, 1887 U.S. LEXIS 2136 (1887)
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Rule of Law:
The President's approval of a court-martial sentence dismissing a commissioned officer is a non-delegable judicial act that requires the President's personal judgment. The official record must affirmatively and unequivocally show that the President personally approved the sentence; it is insufficient for such approval to be merely inferred from a departmental order.
Facts:
- Benjamin P. Runkle, a Major in the U.S. Army, was tried by a general court-martial.
- The court-martial found Runkle guilty and sentenced him to be cashiered (dismissed from service), fined, and imprisoned.
- The Secretary of War, W. W. Belknap, issued an order on January 16, 1873, purporting to execute the sentence.
- This order stated that the proceedings were approved but only explicitly mentioned the President's personal involvement in remitting the fine and imprisonment, stating, 'The President is pleased to remit all of the sentence, except so much thereof as directs cashiering.'
- On the same day, Runkle submitted a petition to President Ulysses S. Grant, asserting that the proceedings had not been lawfully approved by him.
- President Grant received the petition and referred it to the Judge Advocate General for review but took no further action on the sentence's approval.
- Years later, President Rutherford B. Hayes reviewed the case as unfinished business and issued an order formally disapproving the court-martial's findings and sentence.
Procedural Posture:
- Benjamin P. Runkle filed a lawsuit against the United States in the U.S. Court of Claims, seeking pay he argued was owed to him as an Army Major.
- Runkle claimed his dismissal from the Army, based on a court-martial sentence, was legally invalid because the President never properly approved it.
- The Court of Claims rendered a judgment against Runkle, effectively finding the dismissal was valid.
- Runkle appealed the decision of the Court of Claims to the Supreme Court of the United States.
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Issue:
Does an order from the Secretary of War, which does not explicitly state that the President personally approved it, satisfy the statutory requirement that the President must approve a court-martial sentence that dismisses a commissioned officer from service?
Opinions:
Majority - Waite, C.J.
No, an order from the Secretary of War that does not explicitly show it is the result of the President's personal judgment does not satisfy the legal requirement for presidential approval of a court-martial sentence dismissing an officer. The 65th Article of War requires that such sentences be laid before the President for his 'confirmation or disapproval.' This duty is judicial in nature, not administrative, and therefore requires the President's personal judgment, which cannot be delegated. While the President's administrative acts can be executed through heads of departments, a judicial review of a court-martial sentence demands his personal consideration. The record must positively and unequivocally show the President's personal action, and it is not sufficient for jurisdiction to be inferred argumentatively. Here, the Secretary of War's order only mentioned the President's personal action regarding clemency, leaving the approval of the dismissal ambiguous and appearing as a mere departmental act. Subsequent events, including President Hayes's disapproval, confirm that the sentence was never legally executed.
Analysis:
This decision establishes a critical distinction between the President's delegable administrative powers and non-delegable judicial functions. By requiring an affirmative showing of personal presidential judgment for court-martial sentence approvals, the Court set a high standard of authentication for such acts. This precedent reinforces the principle that courts of limited jurisdiction, like courts-martial, are held to strict statutory compliance, and any deviation can render their judgments void. The ruling protects the rights of military officers by ensuring that a career-ending punishment receives review at the highest level of command, preventing it from being treated as a routine departmental matter.
