United States v. Klein
13 Wall. 128 (1871)
Rule of Law:
Congress violates the separation of powers when it passes a law that prescribes a rule of decision for the judiciary in a pending case, or that impairs the legal effect of a presidential pardon.
Facts:
- V. F. Wilson, a citizen, owned certain cotton.
- During the Civil War, Wilson provided aid to the Confederacy.
- The United States government seized Wilson's cotton under the Abandoned and Captured Property Act of 1863.
- The government subsequently sold the cotton and deposited the proceeds into the U.S. Treasury.
- Following the war, Wilson took an oath of allegiance and received a full presidential pardon, which by its terms restored his rights to property.
- Wilson died, and his estate's administrator, United States v. Klein, sought to recover the proceeds from the sale of the cotton.
Procedural Posture:
- Klein, as administrator of Wilson's estate, filed suit against the United States in the Court of Claims to recover the proceeds of the seized cotton.
- The Court of Claims rendered a judgment in favor of Klein.
- The United States appealed the decision to the Supreme Court of the United States.
- While the appeal was pending, Congress passed a proviso in an 1870 appropriation act, directing courts to treat a pardon as proof of guilt and to dismiss such claims for lack of jurisdiction.
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Issue:
Does a federal statute that directs the judiciary to treat a presidential pardon as conclusive proof of guilt and to dismiss a case for want of jurisdiction based on that pardon violate the separation of powers by infringing on the constitutional powers of the executive and judicial branches?
Opinions:
Majority - Chief Justice Chase
Yes. A federal statute that directs the judiciary to treat a presidential pardon as conclusive proof of guilt and to dismiss a case based on that pardon violates the separation of powers. The statute is unconstitutional because Congress cannot prescribe a rule of decision for the judicial department in a pending case. By directing the court to dismiss the case upon finding a pardon was accepted, Congress is not creating new substantive law but is commanding a specific result, thereby invading the province of the judiciary. Furthermore, the statute unconstitutionally infringes on the President's exclusive power to pardon, as a full pardon blots out the offense and all its legal consequences, including any claim the government has on the pardoned individual's property. Congress cannot diminish or negate the legal effect of a pardon granted under the Constitution.
Dissenting - Justice Miller
No, on the underlying property claim, though yes on the unconstitutionality of the proviso. The dissenting justice agrees that the proviso is unconstitutional because the legislative branch cannot impair the force or legal effect of a presidential pardon. However, he disagrees with the majority's interpretation of the Abandoned and Captured Property Act. In his view, once the property of a disloyal owner was seized and sold, title was completely transferred to the government, and the former owner retained no interest. Therefore, a subsequent pardon could not restore property rights that had already been fully and legally extinguished, meaning Klein had no right to the proceeds in the first place.
Analysis:
This case is a landmark decision for the separation of powers doctrine, establishing critical limits on congressional power over the judiciary and the executive. It clarifies that while Congress has power under the Exceptions Clause to regulate the Supreme Court's appellate jurisdiction, it cannot use this power as a pretext to dictate the substantive outcome of pending litigation. The ruling also strongly affirms that the President's pardon power is plenary and cannot be limited or nullified by legislative action, thereby protecting a core executive function from congressional encroachment.
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