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Schell v. Dodge

Citations: 107 U.S. 629; 2 S. Ct. 830; 27 L. Ed. 601; 1882 U.S. LEXIS 1258

Court: Supreme Court of the United States; May 18, 1883; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

Judgments were rendered against a former collector of customs for recovering duties paid, with certificates of probable cause issued for each case. The government moved to dismiss the writs of error without argument, resulting in no affirmance of the lower court's judgments, which had been suspended for over three years. In the Dodge case, the mandate was issued but not presented, while in other cases, mandates were issued and judgments entered without the knowledge of the defendants in error. The defendants now seek to amend the judgments to include interest due to delays. However, the court stated it lacks the authority to alter judgments or mandates after the term has concluded, as no special rights to do so were reserved. The court reaffirmed its position that it cannot modify past judgments regarding dismissals of writs of error to affirmations of lower court judgments. Consequently, the applications for interest were denied.

Legal Issues Addressed

Authority to Amend Judgments Post-Term

Application: The court lacks the authority to amend judgments or mandates after the conclusion of the term, as no special rights to do so were reserved.

Reasoning: However, the court stated it lacks the authority to alter judgments or mandates after the term has concluded, as no special rights to do so were reserved.

Entitlement to Interest Due to Delays

Application: Applications for interest on judgments due to delays were denied as the court lacks the authority to amend judgments post-term.

Reasoning: Consequently, the applications for interest were denied.

Impact of Dismissal of Writs of Error

Application: The court reaffirmed that dismissals of writs of error do not equate to affirmations of lower court judgments, thus limiting the scope for modification.

Reasoning: The court reaffirmed its position that it cannot modify past judgments regarding dismissals of writs of error to affirmations of lower court judgments.