Ableman v. Booth
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| Ableman v. Booth | |
| Reference: 62 U.S. 506 | |
| Term: 1859 | |
| Important Dates | |
| Argued: January 19, 1859 Decided: March 7, 1859 | |
| Outcome | |
| Wisconsin Supreme Court reversed | |
| Majority | |
| Roger B. Taney • John McLean • James Moore Wayne • John Catron • Peter Vivian Daniel • Samuel Nelson • Robert Cooper Grier • John Archibald Campbell • Nathan Clifford | |
Ableman v. Booth is a case decided on March 7, 1859, by the United States Supreme Court holding that state courts cannot issue rulings that contradict the decisions of federal courts. The case concerned whether the Wisconsin Supreme Court had the authority to issue a writ of habeas corpus over a matter relating to a federal prisoner. The Supreme Court reversed the ruling of the Supreme Court of Wisconsin, holding that the state court did not have the authority to issue a writ of habeas corpus.[1][2]
Why it matters: The Supreme Court's decision in this case established that state courts cannot issue rulings that contradict the decisions of federal courts. In cases where a federal court has jurisdiction, the decision is final and cannot be reexamined by a state court. To read more about the impact of Ableman v. Booth click here.
Background
Joshua Glover was a runaway slave who was held in federal custody in Wisconsin. Sherman Booth petitioned the court for Glover's release, which was denied. When Glover escaped, Booth was charged with aiding him which violated the Fugitive Slave Act of 1850. Booth petitioned the Supreme Court of Wisconsin and was released via a writ of habeas corpus.
He was then detained again by the United States District Court for the District of Wisconsin. Booth aimed to appeal his conviction and claimed that the federal court did not have jurisdiction over the case and that the Fugitive Slave Act was unconstitutional. The Supreme Court of Wisconsin released Booth again and Stephen V. R. Ableman, a United States marshal for the district, filed a writ of error with the Supreme Court. The Supreme Court reversed the decision of the state court and established that the Supreme Court of Wisconsin did not have the authority to issue a writ of habeas corpus for a federal prisoner. The Supreme Court also established that state courts did not have the authority to contradict federal decisions and maintained that the Fugitive Slave Act was constitutional.[1][2][3]
Oral argument
Oral argument was held on January 19, 1859. The case was decided on March 7, 1859.[1]
Decision
The Supreme Court decided unanimously to reverse the Supreme Court of Wisconsin's decision. Chief Justice Roger B. Taney delivered the opinion of the court.[1]
Opinions
Opinion of the court
Chief Justice Roger B. Taney, writing for the court, argued that the Supreme Court of Wisconsin did not have the authority or judicial power to issue a writ of habeas corpus outside of their jurisdiction. Taney posited that the state's sovereignty as granted by the Constitution was restricted and could not be applied outside of its limits.[2]
| “ | The judges of the Supreme Court of Wisconsin do not distinctly state from what source they suppose they have derived this judicial power. There can be no such thing as judicial authority unless it is conferred by a Government or sovereignty, and if the judges and courts of Wisconsin possess the jurisdiction they claim, they must derive it either from the United States or the State. It certainly has not been conferred on them by the United States, and it is equally clear it was not in the power of the State to confer it, even if it had attempted to do so, for no State can authorize one of its judges or courts to exercise judicial power, by habeas corpus or otherwise, within the jurisdiction of another and independent Government. And although the State of Wisconsin is sovereign within its territorial limits to a certain extent, yet that sovereignty is limited and restricted by the Constitution of the United States. [4] | ” |
| —Roger B. Taney, majority opinion in Ableman v. Booth[2] | ||
Taney added that any unconstitutional actions should have been determined by the United States, not the state court, and that the decision of the United States District Court should have been final.[2]
| “ | But it can hardly be necessary to point out the errors which followed their mistaken view of the jurisdiction they might lawfully exercise, because, if there was any defect of power in the commissioner, or in his mode of proceeding, it was for the tribunals of the United States to revise and correct it, and not for a State court. And as regards the decision of the District Court, it had exclusive and final jurisdiction by the laws of the United States, and neither the regularity of its proceedings nor the validity of its sentence could be called in question in any other court, either of a State or the United States, by habeas corpus or any other process. [4] | ” |
| —Roger B. Taney, majority opinion in Ableman v. Booth[2] | ||
Taney's opinion also addressed Booth's claim that the Fugitive Slave Law of 1850 was unconstitutional. Taney rejected this claim and argued that Congress had the authority to enact and enforce the law.[2]
| “ | [I]n the judgment of this court, the act of Congress commonly called the fugitive slave law is, in all of its provisions, fully authorized by the Constitution of the United States, that the commissioner had lawful authority to issue the warrant and commit the party, and that his proceedings were regular and conformable to law. [4] | ” |
| —Roger B. Taney, majority opinion in Ableman v. Booth[2] | ||
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: State sovereignty
Ableman v. Booth established that state courts are not permitted to issue rulings that contradict the decision of a federal court. State sovereignty cannot extend beyond the limits of the state's jurisdiction and therefore cannot be used to apply judicial power in a federal case. The text of the case states that:
| “ | The sovereignty of the United States and of a State are distinct and independent of each other within their respective spheres of action, although both exist and exercise their powers within the same territorial limits [4] | ” |
| —Roger B. Taney, majority opinion in Ableman v. Booth[2] | ||
In cases where a federal court has jurisdiction to punish an offense, the decision is final and cannot be reexamined by a state court.
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
- ↑ 1.0 1.1 1.2 1.3 Oyez, "Ableman v. Booth," accessed June 6, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 Justia, "Ableman v. Booth," accessed June 6, 2022
- ↑ Britannica, "Ableman v. Booth," accessed June 7, 2022
- ↑ 4.0 4.1 4.2 4.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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