In re Ayers
 | |
| In re Ayers | |
| Reference: 123 U.S. 443 | |
| Term: 1887 | |
| Important Dates | |
| Argued: November 14-15, 1887 Decided: December 5, 1887 | |
| Outcome | |
| United States Circuit Court for the Eastern District of Virginia reversed | |
| Majority | |
| Stanley Matthews • Morrison Waite • Samuel Freeman Miller • Joseph Bradley • Horace Gray • Samuel Blatchford | |
| Concurring | |
| Stephen Johnson Field | |
| Dissenting | |
| John Harlan I | |
In re Ayers is a case decided on December 5, 1887, by the United States Supreme Court holding that state officers could not be held responsible for breaching a contract between the state and its citizens and were protected from a lawsuit by the Eleventh Amendment of the U.S. Constitution. The case concerned a writ of habeas corpus filed for state officials who had been charged with contempt for violating an order of the United States Circuit Court for the Eastern District of Virginia. The Supreme Court reversed the decision of the circuit court and granted release to the state officials under habeas corpus.[1][2]
Why it matters: The Supreme Court's decision in this case reaffirmed that a suit against a state officer is equivalent to a suit against the state, which is barred by the Eleventh Amendment and made the circuit court's decision void. To read more about the impact of In re Ayers click here.
Background
State officers were charged and convicted of contempt for disobeying an order from the United States Circuit Court for the Eastern District of Virginia. The circuit court had prohibited officers from filing suits "against any person who had tendered the state of Virginia's tax-receivable coupons in payment of taxes due to the state." The state officers were imprisoned and filed for a writ of habeas corpus with the Supreme Court.[2]
Oral argument
Oral argument was held between November 14, 1887, and November 15, 1887. The case was decided on December 5, 1887.[1]
Decision
The Supreme Court decided 7-1 to reverse the decision of the circuit court and granted release to the state officials under habeas corpus. Justice Stanley Matthews delivered the opinion of the court. Justice Stephen Johnson Field wrote a concurring opinion. Justice John Harlan I wrote a dissenting opinion.[1]
Opinions
Opinion of the court
Justice Stanley Matthews, writing for the court, argued that the Eleventh Amendment of the U.S. Constitution grants states sovereign immunity from lawsuits brought by citizens of other states. Matthews referred to the Supreme Court decision in Hagood v. Southern, which established that federal courts did not have jurisdiction over any suit against a state official who was acting on behalf of the state.[1]
| “ | The present case stands upon a footing altogether different. Admitting all that is claimed on the part of the complainants as to the breach of its contract on the part of the State of Virginia by the acts of its General Assembly referred to in the bill of complaint, there is nevertheless no foundation in law for the relief asked. For a breach of its contract by the state it is conceded there is no remedy by suit against the state itself. This results from the Eleventh Amendment to the Constitution, which secures to the state immunity from suit by individual citizens of other states or aliens. This immunity includes not only direct actions for damages for the breach of the contract brought against the state by name, but all other actions and suits against it, whether at law or in equity. A bill in equity for the specific performance of the contract against the state by name it is admitted could not be brought. In Hagood v. Southern, 117 U. S. 52, it was decided that in such a bill, where the state was not nominally a party to the record, brought against its officers and agents, having no personal interest in the subject matter of the suit and defending only as representing the state, where 'the things required by the decree to be done and performed by them are the very things which, when done and performed, constitute a performance of the alleged contract by the state,' the Court was without jurisdiction, because it was a suit against a state. [3] | ” |
| —Stanley Matthews, majority opinion in In re Ayers[1] | ||
Matthews emphasized that the case was a result of a violation of a contract between the state of Virginia and its citizens. He contended that the individual defendants in the case, who were officers of the state, were not capable of breaching said contract because they were not a party to it.
| “ | The acts alleged in the bill as threatened by the defendants, the present petitioners, are violations of the assumed contract between the State of Virginia and the complainants, only as they are considered to be the acts of the State of Virginia. The defendants, as individuals, not being parties to that contract, are not capable in law of committing a breach of it. There is no remedy for a breach of a contract, actual or apprehended, except upon the contract itself and between those who are by law parties to it. In a certain sense and in certain ways, the Constitution of the United States protects contracts against laws of a state subsequently passed impairing their obligation, and this provision is recognized as extending to contracts between an individual and a state; but this, as is apparent, is subject to the other constitutional principle, of equal authority, contained in the Eleventh Amendment which secures to the state an immunity from suit. Wherever the question arises in a litigation between individuals which does not involve a suit against a state, the contract will be judicially recognized as of binding force notwithstanding any subsequent law of the state impairing its obligation. But this right is incidental to the judicial proceeding in the course of which the question concerning it arises. It is not a positive and substantive right of an absolute character, secured by the Constitution of the United States against every possible infraction, or for which redress is given as against strangers to the contract itself, for the injurious consequences of acts done or omitted by them. Accordingly, it was held in Carter v. Greenhow, 114 U. S. 317, that no direct action for the denial of the right secured by a contract, other than upon the contract itself, would lie under any provisions of the statutes of the United States authorizing actions to redress the deprivation, under color of state law, of any right, privilege, or immunity secured by the Constitution of the United States. [3] | ” |
| —Stanley Matthews, majority opinion in In re Ayers[1] | ||
Concurring opinion
Justice Stephen Johnson Field, in a concurring opinion, argued that the suit brought in this case was equivalent to a suit brought against the state of Virginia and was therefore prohibited by the Eleventh Amendment of the Constitution. Field clarified that, although he concurred in the judgment of the present case, he adhered to his dissent in Louisiana v. Jumel in which he posited that the state law in question was unconstitutional.[1]
| “ | I concur in the judgment discharging from arrest and imprisonment the Attorney General of Virginia, and other officers of the state, who were adjudged by the circuit court to be guilty of contempt in refusing to obey the order of that court in the case of Cooper v. Marye, and were fined, and committed until the fine should be paid and they should purge themselves of their contempt by doing the acts commanded. I also concur in the main position stated in the opinion of the Court, upon which the discharge of the petitioners is ordered -- namely that the case of Cooper v. Marye was in law and fact a suit by subjects of a foreign state against the State of Virginia. To a suit of that character the judicial power of the United States cannot, by the Eleventh Amendment of the Constitution, be extended. The object of that suit was to enjoin the attorney general and the commonwealth's attorneys of the several counties, cities, and towns of Virginia from bringing any suits in the name of the commonwealth to enforce the collection of taxes for the payment of which coupons originally attached to her bonds had been tendered. To enjoin the officers of the commonwealth, charged with the supervision and management of legal proceedings in her behalf, from bringing suits in her name is nothing less than to enjoin the commonwealth, for only by her officers can such suits be instituted and prosecuted. This seems to me an obvious conclusion. [3] | ” |
| —Stephen Johnson Field, concurring opinion in In re Ayers[1] | ||
Dissenting opinion
Justice John Harlan I, in a dissenting opinion, argued that the present case was not a case against the state of Virginia and was therefore not protected by the principles of the Eleventh Amendment. Harlan referred to previous decisions of the Supreme Court in which a suit against government officials to recover property was not deemed to be a suit against the United States. He contended that this case should be judged similarly and argued that it was within the jurisdiction of the circuit court to act.[1]
| “ | The result, then, of former decisions is that a suit against officers of the United States to recover property not legally in their possession is not a suit against the United States, and that neither a suit against officers of the state to recover property illegally taken by them in obedience to the statutes of the state nor a suit brought against state officers to enjoin them from taking, under the command of the state, the property of a taxpayer who has tendered coupons for taxes due to her were suits against the state within the meaning of the Eleventh Amendment of the Constitution. And now it is adjudged in the cases before us that a suit merely against state officers to enjoin them from bringing actions against taxpayers who have previously tendered tax receivable coupons is a suit against the state. There is, I grant, a difference between the cases heretofore decided and the case of Cooper v. Marye, but the difference is not such as to involve the jurisdiction of the circuit court, but rather, to use the language of Chief Justice Marshall, 'the exercise of its jurisdiction.' [3] | ” |
| —John Harlan I, dissenting opinion in In re Ayers[1] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Sovereign immunity
In re Ayers reaffirmed that federal courts do not have jurisdiction to act on suits brought against state officers when they are acting on behalf of the state. The decision in this case was built on the precedent established in preceding Supreme Court decisions such as Louisiana v. Jumel and Hagood v. Southern. This decision also highlighted the fact that state officers cannot be held responsible for breaching a contract between a state and its citizens if the officers were not a direct party to the contract.[1]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 Justia, "In re Ayres, 123 U.S. 443 (1887)," accessed July 12, 2022
- ↑ 2.0 2.1 LexisNexis, "In re Ayers - 123 U.S. 443, 8 S. Ct. 164 (1887)," accessed July 12, 2022
- ↑ 3.0 3.1 3.2 3.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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