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United States v. Klein

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United States v. Klein 80 US 128 (1871)

United States v. Klein is one of the most important U.S. Supreme Court cases stemming from the U.S. Civil War (1861-1865).

Background

On 8 December 1863, President Lincoln issued a proclamation offering a pardon to any person who had supported or fought for the South, with full restoration of property rights, subject only to taking an oath of allegiance. Congress had passed an act in 1863 that permitted an owner of property confiscated during the war to receive the proceeds from the sale of the confiscated property.

The Case

Based on the statute and the President's proclamation, V.F. Wilson took the oath of allegiance and honored it until his death in 1864. Mr. Klein, administrator of Mr. Wilson's estate, then applied, properly, to the Court of Claims to recover the proceeds of the sale of property seized from Mr. Klein.

Congress repealed the statute in 1867. The Court of Claims, in 1869, decided that Mr. Wilson's estate was entitled to the proceeds from the sale of his property. Then, in 1870, Congress passed a law that prohibited the use of a Presidential pardon as the basis for claiming sale proceeds, and further said that acceptance of such a pardon was evidence that the person pardoned did provide support to the South and was ineligible to recover sale proceeds. The United States appealed to the Supreme Court, based on the 1870 statute, arguing that since Mr. Wilson had accepted a Presidential pardon and therefore his estate was not entitled to the sale proceeds.

The Decision

In 1871, the Supreme Court ruled that the 1870 statute was unconstitutional and that Congress had exceeded its power by invading the province of the judicial branch by prescribing the rule of decision in a particular cause. The Court also ruled that Congress had impermissibly infringed the power of the executive branch by limiting the effect of a Presidential pardon.

Broadly speaking, Klein stands for the proposition that one branch may not impair the powers of another. Put another way, Klein recognizes and supports the fundamental value of separation of powers defined by the Constitution. Specifically, Klein means that Congress may not direct the outcome of a case by prescribing the rule of decision, nor may Congress impair the power and effect of a Presidential pardon. Read more broadly, Klein suggests, but does not state, that Congress may not use the Exceptions Clause[?] to cripple the Court's ability to be the final arbiter of what the Constitution means.

The essence of the argument is one of separation of powers: that the Constitution vests the judicial power in the judicial branch, and that neither the legislative nor the executive branch may interfere with the functioning of the judiciary. When Congress passed a law that had the effect of prescribing the rule of decision in a particular cause, Congress "inadvertently passed the limit which separates the legislative from the judicial power." Klein, 80 U.S. at 147. As the Court says: "It is the intention of the Constitution that each of the great co-ordinate departments of the government -- the Legislative, the Executive, and the Judicial -- shall be, in its sphere, independent of the others." Id.

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