Ex parte Siebold
| Ex parte Siebold | |
|---|---|
 | |
| Decided October 1, 1879 | |
| Full case name | Ex parte Siebold |
| Citations | 100 U.S. 371 (more) |
| Holding | |
| So long as the vesting is consistent with the separation of powers, Congress has discretion to vest the appointment of an inferior officer in the President, a Department Head, or a Court of Law. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Bradley, joined by Waite, Swayne, Miller, Strong, Hunt, and Harlan |
| Dissent | Field, joined by Clifford |
| Laws applied | |
| U.S. Const. art. II, § 2, cl. 2 | |
Ex parte Siebold, 100 U.S. 371 (1879), was a United States Supreme Court case concerning the separation of powers and the Appointments Clause.
Background
[edit]Baltimore election officials were indicted under the Enforcement Act of 1870 for stuffing ballot boxes and destroying the votes of African Americans in a congressional election. In defense, they contested Congress' authority under the Appointments Clause to control their work as state officials.[1]
Decision
[edit]Writing for the majority, Associate Justice Joseph P. Bradley rejected the officials' claim to independence from federal oversight of their federal elections. Opining that the Fifteenth Amendment to the United States Constitution authorized the Enforcement Act of 1870, he upheld the act.[1]
Legacy
[edit]The Harvard Law Review has deemed this case as an exception to the anti-commandeering doctrine expressed in Printz v. United States (1997), reasoning that it allows the federal government to control state officials and their resources in pursuance of its Elections Clause authority.[2]
References
[edit]- ^ a b Foner, Eric (2019). The Second Founding: How the Civil War and Reconstruction Remade the Constitution. W. W. Norton & Company. p. 148. ISBN 9780393652574.
- ^ "H.R. 1, 116th Cong. (2019)". Harvard Law Review. 133: 1806–1813. March 2020.
External links
[edit]- Text of Ex parte Siebold, 100 U.S. 371 (1879) is available from: Cornell Google Scholar Justia
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