United States v. Klein, 80 U.S. 128 (1871).

pp. 14–15.

Facts

  • In 1863, Congress adopted a statute providing that individuals whose property had been seized during the Civil War could recover their property or just compensation for it if they proved they had not assisted the Confederate Army during the Civil War.
    • President Abraham Lincoln then issued a proclamation offering a pardon to anyone who had fought for or supported the Confederate Army, provided that person took an oath of allegiance to the Union.
    • Following Congress’s act and the president’s proclamation, the United States Supreme Court held that a presidential pardon was sufficient proof that an individual had not assisted the Confederate Army and was enough to justify a restoration of that person’s property rights.
  • Based on the 1863 statute and the president’s proclamation, V. F. Wilson took the oath of allegiance and was pardoned.
    • After Wilson’s death in 1865, the administrator of his estate, Klein (defendant), applied to the Court of Claims to recover compensation for property seized from Wilson during the Civil War.
  • In 1867, while Klein’s case was pending, Congress repealed its 1863 statute.
    • The Court of Claims then decided in 1869 that Wilson’s estate was entitled to compensation for seized property based on his oath and presidential pardon.
  • However, in 1870, Congress passed a new law that prohibited the use of a presidential pardon as proof that an individual was entitled to property rights or compensation.
    • The law also said that acceptance of a presidential pardon, without a specific disclaimer of guilt, was conclusive evidence that the person did provide support to the Confederacy and thus made that person ineligible to recover property or compensation.
  • Congress stated that if a person was ultimately found to support the Confederacy, the United States Supreme Court had no jurisdiction over an appeal of his or her denial of property rights from the Court of Claims.
  • Based on this new law, the United States government (plaintiff) brought suit in the United States Supreme Court challenging the property rights given to Klein on the grounds that since Wilson accepted a presidential pardon, his estate was not entitled to property or sale proceeds.

Issue

  • May Congress constitutionally pass legislation that specifically directs or impairs the actions of the judicial or executive branches of government?

Holding

  • No. Under the Constitution’s grant of power to Congress to make “such exceptions to appellate jurisdiction” as it deems appropriate, Congress could permissibly limit the ability of the Supreme Court to hear certain cases on appeal.

Reasoning

  • However, in this case, Congress’s 1870 law did more than just make exceptions to the Court’s appellate jurisdiction.
  • It went beyond that to actually require the Court to determine it was without jurisdiction if it found that a plaintiff was entitled to property rights based on a presidential pardon.
    • This effectively required the Supreme Court to reach a certain result; it prescribed the rule of decision in a particular case.
  • This is an impermissible extension of Congress’s power and is thus unconstitutional.
  • Additionally, Congress also exceeds its powers by limiting the effect of a presidential pardon—a distinctively executive act.
    • The judgment for Klein is affirmed because Congress overstepped its bounds and violated the principle of separation of powers in the United States Constitution.

Notes

  • Takeaway: when Congress narrows the judiciary's jurisdiction so far as to force it to rule in practically one way for each concerned case, Congress has overstepped and breached separation of powers—as it has substituted the judiciaries ability to decide cases in controversy with its own decision.
    • Based on the principle of separation of powers in the United States Constitution, the legislative branch may not impair or direct the exclusive powers of the judicial or executive branches.