Supreme Court Revisionism

The New York Times reported recently:

The Supreme Court has been quietly revising its decisions years after they were issued, altering the law of the land without public notice.”

For example, this past April, Justice Scalia made a misstep in a dissent in a case involving the E.P.A. Under the heading “Plus Ça Change: E.P.A.’s Continuing Quest for Cost-Benefit Authority,” he criticized the EPA for seeking cost-benefit authority in a 2001 case. But as the New York Times noted, that “he got its position backward. Worse, he was the author of the majority opinion in the 2001 decision.”

After law professors pointed out the mistake, Justice Scalia quickly altered the opinion, revising the text and substituting the heading “Our Precedent.”

Justice Scalia, proponent of "originalism" except in the case of his own opinions

Justice Scalia, proponent of “originalism” except in the case of his own opinions

Now, there is a way to find out quickly and easily when revisions happen. David Zvenyach, General Counsel to the Council of the District of Columbia, recently launched @Scotus_servo, a Twitter account that alerts followers whenever a change is made to a Supreme Court opinion.

The process uses an application written in JavaScript that crawls through the “slip” opinions posted to the Supreme Court website. If the application, which performs a crawl every five minutes, detects a change, it notifies the automated Twitter account, which tweets out an alert. Shortly thereafter, Zvenyach sends out a manual tweet that calls attention to the change. Here is an example:

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Since Zvenyach launched his twitter account, Joshua Tauberer (@JoshData) came up with a way to highlight the changes and he tweets them out in a “before” and “after” format like this example:

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These changes should make interesting complications for legal researchers.

June 14, 1943 – Justice Jackson Fixes A Star in our Constitutional Constellation

On this date, the Supreme Court decided West Virginia State Board of Education v. Barnette (319 U.S. 624).

The Court’s opinion, delivered by Justice Robert H. Jackson, held that the Free Speech Clause of the First Amendment to the United States Constitution protected students from being forced to salute the American flag and say the Pledge of Allegiance in school.

It might be noted in addition that up until 1942, many children in America used the “Bellamy salute” to accompany the American Pledge of Allegiance. (Francis Bellamy authored the Pledge, and described the salute shown below to accompany it.) After the Fascists adopted this style of salute, Congress officially adopted the hand-over-heart stance to be used while the Pledge is recited.

American students citing the Pledge with the Bellamy salute

American students citing the Pledge with the Bellamy salute

In West Virginia State Board of Education v. Barnette, Justice Jackson memorably wrote:

If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion, or force citizens to confess by word or act their faith therein.”

Justice Robert H. Jackson

Justice Robert H. Jackson

June 1, 1916 – Louis Brandeis Joins the Supreme Court

On this date, Louis Brandeis began serving as the first Jewish member of the Supreme Court. His nomination, by President Woodrow Wilson, was bitterly contested. The controversy surrounding Brandeis’s nomination was so great that the Senate Judiciary Committee, for the first time in its history, held a public hearing on the nomination, allowing witnesses to appear before the committee and offer testimony both in support of and in opposition to Brandeis’s confirmation.

Justice William O. Douglas wrote in 1964 that the nomination of Brandeis “frightened the Establishment”:

Brandeis was a militant crusader for social justice whoever his opponent might be. He was dangerous not only because of his brilliance, his arithmetic, his courage. He was dangerous because he was incorruptible.”

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May 15, 1911 – The Supreme Court Orders the Dissolution of the Standard Oil Company

On this day in history, the Supreme Court ruled, in Standard Oil Co. of New Jersey v. United States (221 U.S. 1) that the Standard Oil Company was in violation of the Sherman Anti-trust Act of 1890 (26 Stat. 209). The Court’s remedy was to divide Standard Oil into several geographically separate and eventually competing firms.

You can read our detailed analysis of this case, here.

1904 Political cartoon showing a Standard Oil tank as an octopus with many tentacles wrapped around the steel, copper, and shipping industries, as well as a state house, the U.S. Capitol, and one tentacle reaching for the White House.

1904 Political cartoon showing a Standard Oil tank as an octopus with many tentacles wrapped around the steel, copper, and shipping industries, as well as a state house, the U.S. Capitol, and one tentacle reaching for the White House.

April 7, 2003 – The Supreme Court Decides Virginia v. Black

In the 2003 case Virginia v. Black (538 U.S. 343), three defendants were convicted in two separate cases of violating a Virginia statute against cross burning. In an opinion authored by Justice Sandra Day O’Connor, the Court struck down Va. Code Ann. §18.2—423 (1996) to the extent that it considered cross burning as prima facie evidence of intent to intimidate:

We conclude that while a State, consistent with the First Amendment, may ban cross burning carried out with the intent to intimidate, the provision in the Virginia statute treating any cross burning as prima facie evidence of intent to intimidate renders the statute unconstitutional in its current form.”

In the opinion, Justice O’Connor recounted the history of the Ku Klux Klan and the display of a burning cross “used to communicate both threats of violence and messages of shared ideology.” She cited the Klan constitution which claims that the “fiery cross” is the “emblem of that sincere, unselfish devotedness of all klansmen to the sacred purpose and principles we have espoused.” She also adduced instances in which the burning cross was used by the Klan as “a sign of celebration and ceremony” such as at a marriage of two Klan members. Nevertheless, she acknowledged:

…while a burning cross does not inevitably convey a message of intimidation, often the cross burner intends that the recipients of the message fear for their lives. And when a cross burning is used to intimidate, few if any messages are more powerful.”

Justice Sandra Day O'Connor

Justice Sandra Day O’Connor

Nevertheless, she was unwilling to compromise the First Amendment, applicable to the States through the Fourteenth Amendment, providing that “Congress shall make no law … abridging the freedom of speech.” Citing previous rulings of the Court, she observed: “The hallmark of the protection of free speech is to allow “free trade in ideas”–even ideas that the overwhelming majority of people might find distasteful or discomforting.”

She admitted that “Virginia’s statute does not run afoul of the First Amendment insofar as it bans cross burning with intent to intimidate.” But the Court agreed with the Supreme Court of Virginia in its finding that the Virginia statute was “overbroad” in inferring intent from the burning of a cross by itself:

As the history of cross burning indicates, a burning cross is not always intended to intimidate. Rather, sometimes the cross burning is a statement of ideology, a symbol of group solidarity. It is a ritual used at Klan gatherings, and it is used to represent the Klan itself. Thus, “[b]urning a cross at a political rally would almost certainly be protected expression.” R. A. V. v. St. Paul, 505 U.S., at 402, n. 4 (White, J., concurring in judgment) (citing Brandenburg v. Ohio, 395 U.S., at 445). Cf. National Socialist Party of America v. Skokie, 432 U.S. 43 (1977) (per curiam). Indeed, occasionally a person who burns a cross does not intend to express either a statement of ideology or intimidation. Cross burnings have appeared in movies such as Mississippi Burning, and in plays such as the stage adaptation of Sir Walter Scott’s The Lady of the Lake.”

Justice O’Connor did not address what would constitute sufficient proof of “intent to intimidate.” It seems she was willing to accept any explanation offered by Klan members, notoriously not given to self-incrimination.

In his dissent, Justice Clarence Thomas basically writes, “Oh, come on!” He argues:

In our culture, cross burning has almost invariably meant lawlessness and understandably instills in its victims well-grounded fear of physical violence.”

Justice Clarence Thomas

Justice Clarence Thomas

In addition he contended that the Virginia statute prohibited only conduct, not expression. However, he clarified:

Even assuming that the statute implicates the First Amendment, in my view, the fact that the statute permits a jury to draw an inference of intent to intimidate from the cross burning itself presents no constitutional problems. Therein lies my primary disagreement with the plurality.”

He went on to note that in other instances of potential harm, the Court had not imposed a scienter requirement. Indeed, he averred, “Considering the horrific effect cross burning has on its victims, it is also reasonable to presume intent to intimidate from the act itself.” He concluded:

…the plurality strikes down the statute because one day an individual might wish to burn a cross, but might do so without an intent to intimidate anyone. That cross burning subjects its targets, and, sometimes, an unintended audience, see 262 Va., at 782; see also J.A. 93—97, to extreme emotional distress, and is virtually never viewed merely as “unwanted communication,” but rather, as a physical threat, is of no concern to the plurality. Henceforth, under the plurality’s view, physical safety will be valued less than the right to be free from unwanted communications.”

In 2002, the Virginia legislature responded by enacting a new statute numbered § 18.2-423.01. The original Section 18.2-423, held unconstitutional, has not been repealed. The new statute, however, does not contain a prima facie evidence provision and applies to “objects,” not mentioning crosses in particular. The statute makes burning an object on the private property of another with the intent to intimidate a crime in itself; whereas, burning an object on a highway or other public place with the intent to intimidate must be “in a manner having a direct tendency to place another person in reasonable fear or apprehension of death or bodily injury.”

Ku Klux Klansmen and women at a cross "lighting" (as opposed to "burning") on November 12th, 2005.

Ku Klux Klansmen and women at a cross “lighting” (as opposed to “burning”) on November 12th, 2005.

March 18, 1963 – The Supreme Court Decided Gideon V. Wainwright; What Were Its Effects?

On this day in history, the Supreme Court ruled that the states are required to provide legal counsel to criminal defendants who are unable to pay for their own defense. You can read the full decision here and you can read our explication of the case here.

Source: Monk, Linda R. The Bill Of Rights: A User's Guide. Close-Up Publishing: 1991. p. 152.

Source: Monk, Linda R. The Bill Of Rights: A User’s Guide. Close-Up Publishing: 1991. p. 152.

Notably, Justice Hugo Black stated in his opinion:

The right of one charged with crime to counsel may not be deemed fundamental and essential to fair trials in some countries, but it is in ours. From the very beginning, our state and national constitutions and laws have laid great emphasis on procedural and substantive safeguards designed to assure fair trials before impartial tribunals in which every defendant stands equal before the law. This noble ideal cannot be realized if the poor man charged with crime has to face his accusers without a lawyer to assist him.” 372 U.S. 335 at 344

Unfortunately, the right to “counsel” doesn’t always guarantee competent counsel. A 2009 report published by The National Right to Counsel Committee, Justice Denied: America’s Continuing Neglect of Our Constitutional Right to Counsel, identified grave problems in the provision of legal representation for the poor, especially because of chronic underfunding. As the report notes:

When the defense does not measure up to the prosecution, there is a heightened risk of the adversary system of justice making egregious mistakes.”

Analyzing Gideon more specifically, in June, 2013, The Yale Law Journal published a special issue on Gideon, which you can access free online here.

For example, John H. Blume, Professor of Law at Cornell Law School and Sheri Lynn Johnson, James and Mark Flanagan Professor of Law at Cornell Law School, argue in Gideon Exceptionalism, 122 YALE L.J. 2126 (2013):

As we set forth in this Essay, we think Gideon is both a “shining city on a hill” in the world of criminal procedure and something of a sham. We first discuss the extraordinary features of the decision itself, then lay out how it has survived largely intact, unlike virtually all other Warren Court criminal procedure decisions. Then we turn to the bleaker side of the Gideon story, first illuminating how the stingy law of ineffective assistance of counsel renders Gideon’s “shining city” illusory for many defendants, and then showing how the routine denial of investigative and expert assistance to indigent defendants further undercuts Gideon’s promise.”

Paul Butler, Professor at Georgetown University Law Center, exposes a broader problem, in Poor People Lose: Gideon and the Critique of Rights, 122 YALE L.J. 2176 (2013). He contends:

A low income person is more likely to be prosecuted and imprisoned post-Gideon than pre-Gideon. Poor people lose in American criminal justice not because they have ineffective lawyers but because they are selectively targeted by police, prosecutors, and law makers. The critique of rights suggests that rights are indeterminate and regressive. Gideon demonstrates this critique: it has not improved the situation of most poor people, and in some ways has worsened their plight. Gideon provides a degree of legitimacy for the status quo. Even full enforcement of Gideon would not significantly improve the loser status of low-income people in American criminal justice.”

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There is also an excellent resource on the website of The Brennan Center, providing a list of links to articles examining the effects of Gideon fifty years after the decision, prefacing it with the observation:

The average amount of time spent by a public defender at arraignment is often less than six minutes per case. And that is when counsel is present and allowed to give information.”

Particularly recommended is the editorial by Georgetown Law Professor Paul Butler in The New York Times, who recounts some of the more egregious instances of “Gideon’s Muted Trumpet.”

Additionally, the American Bar Association has a list of resources related to the fiftieth anniversary of Gideon, which you can access here.

March 1, 1842 – The U.S. Supreme Court Decided Prigg v. Pennsylvania

Prigg v. Pennsylvania, 41 U.S. 539 (1842) is considered to be one of the most important Supreme Court decisions on slavery.  In this case, a badly split court (the decision included seven separate opinions, a rare practice in antebellum America), held that a Pennsylvania state law prohibiting blacks from being taken out of Pennsylvania into slavery was unconstitutional.

The Fugitive Slave Clause of the U.S. Constitution (Article 4, Section 2, Clause 3 superseded by the Thirteenth Amendment) provided: 

No person held to service or labor in one State, under the laws thereof, escaping into another, shall, in consequence of any law or regulation therein, be discharged from such service or labor, but shall be delivered up on claim of the party to whom such service or labor may be due.”

 
That clause clearly prohibited the Northern states from “discharging” any former slaves from their obligations of “service or labor,” but did not provide a mechanism for slave owners to recover their slaves.  The clause said only that the slaves shall be “delivered up” [by whom is unstated] upon assertion of a “claim.”   

Congress passed the 1793 Fugitive Slave Act to provide specific procedures and remedies for slave owners. However, Sections 3 and 4, which dealt with the rendition of fugitive slaves, neither vested responsibility for the enforcement of the law in any person or official nor set a standard by which the seized person’s status as a fugitive was to be proved.

In 1826 Pennsylvania passed an extensive anti-kidnapping law, making it difficult under Pennsylvania law to kidnap blacks or mulattos to take them into slavery or servitude.

In 1837, Edward Prigg entered the state of Pennsylvania as the agent of Margaret Ashmore, a slave owner from Maryland, in order to find Ashmore’s alleged escaped slave Margaret Morgan. Pennsylvania law required Prigg to show documentary evidence proving Ashmore’s ownership for the legal removal of Morgan and her two children.  The state magistrate to whom Prigg submitted his evidence denied his “claim.” Prigg seized the family nonetheless, and removed them to Maryland.  Indicted and convicted under Pennsylvania’s anti-kidnapping statute, Prigg appealed on the grounds that Pennsylvania’s law violated both Article IV of the Constitution and the federal Fugitive Slave Law of 1793.

The case raised numerous issues, among them the complicated definition of the status of Margaret Morgan, the supposed slave in question. Her parents had been the slaves of a Marylander named Ashmore. Without formally emancipating them, sometime before 1812 he allowed them to live as free blacks.   Margaret was born subsequent to this informal declaration.  She grew up and married a free black, and they moved across the state line to Pennsylvania, all with the acquiescence of the senior Ashmore. Regardless of their status, their several children were free under Pennsylvania law. 

When Ashmore died, his estate passed to his niece Margaret. Her husband, Nathan Bemis, hired Prigg and two others to go with him to retrieve and enslave Margaret Morgan. Historian Paul Finkelman opines: “The fact that Bemis and Prigg were immediately able to locate Morgan suggests that she did not see herself as a fugitive slave and had never tried to hide her whereabouts from Ashmore or his niece. That the Morgans lived along the Maryland border also suggests they believed Margaret was a free person.”  (Paul Finkelman, “Sorting out Prigg v. Pennsylvania,” 24 Rutgers L.J. 605, 611 1992-1993) 

Nevertheless, and after being denied authorization by a Pennsylvania Justice of the Peace, Prigg and Bemis took Margaret and the children (but not the husband) to Maryland where they were sold to a trader for shipment to the South.  Clearly Bemis was not interested in getting back a slave but in punishing a presumptuous black. However, the Fugitive Slave Act placed no limitations on what could or could not be done with recovered slaves. In any event, the question of whether Margaret and her children should have even been considered as slaves was a fuzzy one.

(Justice McLean, in dissent, addressed these ambiguities extensively).

In addition, the case highlighted the increasing animosities between slave and free states, which did not always cooperate with one another in matters of extradition.  (The Supreme Court did not decide whether states could be compelled to cooperate with extradition requests until Kentucky v. Dennison, 65 U.S. (24 How.) 66, 1861.)

Most importantly, the case raised the issue of the interplay of state and federal power.  

Writing for the Court, Justice Joseph Story reversed Prigg’s conviction, ruling that the Pennsylvania act was unconstitutional, at least as applied to fugitive former slaves.

Justice Joseph Story, 1844

Justice Joseph Story, 1844

He held that Congress had exclusive jurisdiction in this area, citing The Federalist to bolster his argument that the rights and duties imposed by the Constitution implies a remedy, “and where else would the remedy be deposited (Madison asked in The Federalist), than where it is deposited by the Constitution?”  (Prigg at 617).  But while all of the justices agreed that the states could not pass laws creating additional requirements to the federal law or impeding the return of fugitive slaves, they disagreed on how to define these terms; what obligation state officials had to aid in the rendition process; and if they did have such an obligation, what it should be.

Justice Story noted that the section of the Act of 1793 conferring jurisdiction on state magistrates was very troublesome, expressing doubt that Congress had power to compel state judges to act.  He stated that state officials had no obligation to enforce federal penal law in this area because the Constitution does not provide for “any state functionaries, or any state action, to carry its provisions into effect.” (at 615) Presumably Story was trying to lay the basis for a possible legislative attack upon slavery in the future.  His son, at any rate, in his biography of his father (Life and Letters of Joseph Story by William Wetmore Story) argued that his father’s opinion constituted a not-too-subtle sabotage of the practical enforceability of the Fugitive Acts.

Others, however, argue that Justice Story actually aided in nationalizing the institution.  As Finkleman observes:

Any notion of freedom – or even of the localization of slavery – in the opinion has to be balanced against Story’s assertions that the master’s right to his slave was “positive,” “unqualified,” and “absolutely secured.”  As Story’s greatest biographer noted, “[H]ere, in language all too plain for some, was an argument for the return of fugitive slaves anchored solidly in the Constitution and backed by the greatest living authority on American constitutional law.” (citations omitted; Finkleman, op. cit. at 659)

The question of interpretation is relevant because Justice Story was known as a passionate advocate of abolition.  In 1819, he even publicly called for the eradication of slavery from the territories.  He also wrote the famous opinion for United States v. The Amistad (40 U.S. 518, 1841)  ruling that the Africans on board the Amistad were free individuals; that having been kidnapped and transported illegally, they had never been slaves.

On the other hand, he recognized that appeasing the slave-holding states had been necessary to make an American union possible, and in Prigg even characterized the Fugitive Slave Act as an indispensable element in that regard.  He wrote that the Constitution gave slave holders:

…complete right and title of ownership in their slaves as property in every State in the Union into which they might escape from the State where they were held in servitude. The full recognition of this right and title was indispensable to the security of this species of property in all the slaveholding States, and indeed was so vital to the preservation of their domestic interests and institutions that it cannot be doubted that it constituted a fundamental article without the adoption of which the Union could not have been formed.” (Prigg at 540)

In spite of his personal loathing of the Fugitive Slave Act, he perceived his primary obligation to be to the Constitution.  Of course, Lincoln’s position was quite similar, and like Story, Lincoln decided that although the rule of law should obtain, there was more than one way to skin the cat.

But both Story and Lincoln faced a formidable obstacle in the Chief Justice of the Supreme Court, Roger Taney, whose concurrence in Prigg  averred:

I dissent, therefore, … from that part of the opinion of the court which denies the obligation and the right of the state authorities to protect the master, when he is endeavoring to seize a fugitive from his service, in pursuance of the right given to him by the constitution of the United States; provided the state law is not in conflict with the remedy provided by congress.”

The Prigg decision angered opponents of slavery.  As the famous abolitionist Wendell Phillips lamented the next year, when another fugitive slave challenge arose:

There stands the bloody [fugitive slave] clause – you cannot fret the seal off the bond.  The fault is in allowing such a Constitution to live an hour….”  (W. Phillips, Speech at Faneuil Hall, Boston, Oct. 30, 1842, quoted in I. Bartlett, Wendell Phillips: Brahmin Radical, 1961)

Following Prigg, however, some state judges refused to participate in federal fugitive slave proceedings, and there were not enough federal magistrates to process applications. Southern slaveholders then agitated for new legislation, which they received as part of the famous “Compromise of 1850,” a package of legislative measures enacted by Congress to reconcile the differences existing between the North and South concerning the issue of slavery in newly formed U.S. territories. The Fugitive Slave Act of 1850 authorized the appointment of a federal commissioner in every county in the United States who could issue certificates of removal for fugitive slaves. It also added additional punishments for lack of citizen cooperation, and denied a slave the benefit of a trial. The statements of the alleged slave’s owner (who did not even have to appear in court) would constitute sufficient evidence for the action.

It would take a war to imbue the Constitution with moral justice.

February 23, 2011 – The U.S. DOJ Announced It Would No Longer Defend DOMA

On this day in history, the Department of Justice released a statement by Eric H. Holder, Jr., the 82nd Attorney General of the United States, declaring:

[President Obama] has concluded that given a number of factors, including a documented history of discrimination, classifications based on sexual orientation should be subject to a more heightened standard of scrutiny. The President has also concluded that Section 3 of DOMA, as applied to legally married same-sex couples, fails to meet that standard and is therefore unconstitutional.   Given that conclusion, the President has instructed the Department not to defend the statute in such cases.”

Eric Himpton Holder, Jr.

Eric Himpton Holder, Jr.

Much controversy ensued over the putative duty of the executive branch to defend laws enacted by the legislative branch. In light of this uproar, Neal Devins (Goodrich Professor of Law and Professor of Government, College of William and Mary) and Saikrishna Prakash (David Lurton Massee, Jr., Professor of Law & Sullivan & Cromwell Professor of Law, University of Virginia), made a detailed analysis of whether there is in fact (i.e., in law), any basis for this charge. You can read their arguments, posted from the Columbia Law Review, here, which in essence find:

…there simply is no duty to defend federal statutes the President believes are unconstitutional. Contrary to his defenders, there likewise is no duty to enforce such laws. Given President Obama’s belief that the DOMA is unconstitutional, he should neither enforce nor defend it.”

On June 26, 2013, The Supreme Court, in United States v. Windsor, struck down part of DOMA, holding that it “violates basic due process and equal protection principles applicable to the Federal Government.”

Justice Anthony M. Kennedy wrote the majority opinion and was joined by Justices Ruth Bader Ginsburg, Stephen G. Breyer, Sonia Sotomayor and Elena Kagan. Chief Justice John G. Roberts Jr. wrote a dissenting opinion, as did Justice Antonin Scalia, whose opinion was joined by Justice Clarence Thomas and Justice Roberts in part. Justice Samuel A. Alito Jr. filed another dissenting opinion, which Justice Thomas joined in part.

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February 9, 1953 – Justice Robert H. Jackson Clarifies the Role of the Supreme Court

Brown v. Allen (344 U.S. 443) was part of a group of cases that was reargued before the Supreme Court since, as Justice Stanley Reed explained in writing his decision for the Court:

As the records raised serious federal constitutional questions upon which the carrying out of death sentences depended and procedural issues of importance in the relations between states and the federal government upon which there was disagreement in this Court, we decided to set the cases for reargument.”

Justice Stanley Forman Reed

Justice Stanley Forman Reed

This decision is notable because, beginning with this case, the Supreme Court expanded access to federal habeas corpus review for state prisoners. It is also in this decision that Justice Jackson offered, in his concurrence, his famous view about the nature of the Supreme Court, opining:

We are not final because we are infallible, but we are infallible only because we are final.”

Neither Justice Reed nor Justice Jackson, by the way, ever graduated law school.

Justice Robert H. Jackson

Justice Robert H. Jackson

January 31, 1801 – John Marshall is Appointed Chief Justice of the U.S. Supreme Court

On this date in history, John James Marshall was appointed to be the fourth Chief Justice of the United States by President John Adams. Marshall dominated the Court for over three decades, serving as Chief Justice during all or part of the administrations of six presidents: John Adams, Thomas Jefferson, James Madison, James Monroe, John Quincy Adams and Andrew Jackson. He helped to establish the Supreme Court as the final authority on the meaning of the Constitution in cases and controversies that must be decided by the federal courts.

John Marshall

John Marshall

President John Adams is said to have told Marshall’s son in 1826, “My gift of John Marshall to the people of the United States was the proudest act of my life. There is no act of my life on which I reflect with more pleasure.”

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