Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Field v. Clark
Citations: 143 U.S. 649; 12 S. Ct. 495; 36 L. Ed. 294; 1892 U.S. LEXIS 2046Docket: 1,052
Court: Supreme Court of the United States; February 28, 1892; Federal Supreme Court; Federal Appellate Court
Justice Hablan delivered the court's opinion regarding the assessment and collection of duties under the Tariff Act of October 1, 1890, on various imported goods by Marshall Field & Co., Boyd, Sutton & Co., and Herman, Sternbach & Co. The importers contested the validity of the act on the basis that it was not a law of the United States. Upon appeal, the Board of General Appraisers upheld the collector's decisions, which were subsequently affirmed by the Circuit Courts. The appellants challenged the act's validity on three grounds, particularly invoking the constitutional requirement that all revenue-raising bills originate in the House of Representatives. The excerpt details the legislative process outlined in the Constitution for bills, including the role of the President and the necessary approvals by both houses of Congress. The original act, H. R. 9116, was received by the Department of State on October 1, 1890, and bore the signatures of key congressional figures, indicating it had been approved and certified as properly originating in the House. The Secretary of State is mandated to provide the Congressional Printer with a correct copy of every act and joint resolution promptly after Presidential approval or constitutional enactment. This duty was fulfilled regarding the act in question, which is included in the published volume of statutes. The appellants argue that the act should be considered null and void because a section of the bill, as passed, was not included in the version authenticated by the signatures of Congress's presiding officers and the President. The omitted section relates to tax rebates on tobacco products, detailing the conditions and authority for administering such rebates. The appellants assert that a bill cannot become law if it was not properly passed by Congress, emphasizing that the signatures of Congressional leaders and the President do not validate a bill lacking Congressional passage. The court acknowledges the validity of this principle but must examine the evidence regarding whether the bill was indeed passed by Congress, a matter it is addressing for the first time. The court is committed to upholding constitutional requirements for law enactment across the United States. The court faces significant implications if it declares an enrolled bill—validated by the signatures of Congress's presiding officers and the President—not passed by Congress, thereby negating its status as law. The appellants argue this based on the constitutional requirement for each house to maintain a journal of proceedings, suggesting it serves as definitive evidence of a bill's passage. However, the interpretation of this clause emphasizes transparency and accountability rather than serving as the sole proof of legislative action. The clause aims to prevent secrecy in legislative processes and promote public awareness and representative responsibility. The Constitution does not mandate a specific method for authenticating the passage of bills, leaving this to congressional discretion. Although not explicitly required, the long-standing practice necessitates signatures from the presiding officers to attest that a bill has been duly passed, thereby fulfilling constitutional obligations before presentation to the President. Approval of a bill by the President, followed by its deposit in public archives, constitutes complete and unimpeachable authentication that it has passed Congress. The President cannot approve a bill that has not been passed, meaning an enrolled act, once in the custody of the Secretary of State and bearing the official attestations of the Speaker of the House, the President of the Senate, and the President, provides a solemn assurance that it was duly passed. The judicial branch is obliged to accept such authenticated bills as having passed Congress, with the courts only determining constitutional conformity when relevant issues arise. It is acknowledged that an enrolled act serves as sufficient evidence of passage unless contradicted by its text. However, some argue that a bill cannot be considered a law if the journal of either house does not reflect its exact form as signed by the presiding officers and the President. This concern, however, is viewed as an unlikely conspiracy theory involving multiple officials, which undermines respect for coequal branches of government. The potential issues from recognizing that an enrolled act, with proper custody and attestation, is conclusive evidence of Congressional passage are deemed less significant than the consequences of making enactments dependent on the accuracy of legislative journals. The principles laid out are supported by case law, such as in Pangborn v. Young, where the court emphasized that the constitutional requirement for legislative journals should not be interpreted as creating conclusive evidence of legislative conformity. The Chief Justice criticized the reliability of legislative journals, asserting that they are often hastily compiled and lack authentication, raising concerns about their use as evidence to evaluate state laws. He warned that if laws were judged by such imperfect records, it could undermine the stability of written law, potentially exposing many statutes to scrutiny and invalidation based on minor alterations. This vulnerability could lead to significant legal uncertainties, risking corruption of legislative evidence. The Chief Justice emphasized that a properly signed and approved copy of a bill, held by the Secretary of State, serves as conclusive proof of a statute’s enactment and content, superseding any claims based on legislative journals or other less authoritative sources. This view aligns with precedents established by various courts, including the New Jersey Court of Errors and Appeals and the California Supreme Court, which support the notion that legislative records should not be challenged by less reliable documentation. The prevailing legal principle is that, at common law, the existence of a statute cannot be disputed based on the journals or other informal records, and any misrecitation must be resolved by the court as a matter of law, reinforcing the rule that official enrollment of statutes is conclusive unless explicitly altered by constitutional or statutory requirements. The California constitutional provisions regarding legislative journals were similar to those in the U.S. Constitution at the time the referenced case was decided. The principles established in this case were reaffirmed in People v. Burt. Subsequent to the case, California adopted a new constitution allowing for the journals to be used to challenge the validity of enrolled bills, as seen in County of San Mateo v. Southern Pacific Railroad Co. A pertinent case is Ex parte Wren, where the court addressed the validity of an act that, although signed by legislative leaders and the governor, did not reflect certain amendments made by the legislature. The court, led by Justice Campbell, concluded that the signed enrolled act is the definitive representation of its contents and that examining legislative history through journals is impermissible. This approach maintains the legislature's status as a coequal branch of government and prevents excessive litigation and uncertainty regarding laws. If courts could assess statutes based on legislative journals, every level of the judiciary would be burdened with verifying legislative records, leading to a chaotic legal landscape. The court emphasized that courts should accept statutes as enacted when properly authenticated by the legislature, citing Weeks v. Smith to highlight the potential errors in legislative journals compared to the reliability of presiding officers' certifications. Public policy dictates that the enrolled statutes of the State, which appear valid, should not be questioned after public trust has been established in their legitimacy. Individuals should not be expected to scour legislative journals to verify the status of a statute that is properly certified and approved by the relevant authorities. Enrolled acts, whether public or private, are recognized as authoritative records in England, possessing inherent veracity unless they exhibit clear defects. Various case precedents from other states affirm this principle, although some diverge based on specific constitutional or statutory requirements that allow courts to investigate the authenticity of enrolled acts. Notably, Illinois cases highlight that under their Constitution, the validity of a bill is contingent upon adherence to procedural requirements recorded in legislative journals. However, the Illinois court acknowledged that a different rule might have equally served public interests. The case of Gardner v. The Collector illustrated that courts can reference legislative journals to clarify details such as the effective date of a statute when not explicitly stated in the enrolled act. This principle, however, does not address the core question of the validity of the statute itself. The cases South Ottawa v. Perkins, Walnut v. Wade, and Post v. Supervisors affirm that whether a legislative act is constitutional is a judicial matter, not one for a jury. The court referenced prior Illinois Supreme Court decisions, allowing judicial consultation of legislative journals to assess the validity of enrolled acts. However, the court clarified that the statutory provision regarding legislative journal extracts does not establish the journals as the definitive evidence of legislative processes. Specifically, the authenticated enrolled bill cannot be challenged by discrepancies in the journals. Consequently, the appellants are not permitted to prove, through legislative journals or other documents, that the enrolled bill H. R. 9416 included provisions absent from the official enrolled act held by the State Department. Additionally, the excerpt details the powers granted to the President under the act of October 1, 1890, to suspend trade provisions based on reciprocity, particularly regarding duties on certain imported goods, specifying tariff rates based on sugar color classifications determined by polariscope testing. All sugars classified above number thirteen on the Dutch color standard are subject to specific duties: sugars above number thirteen but not exceeding number sixteen are taxed at one and three-eighths cents per pound; those above sixteen but not exceeding twenty at one and five-eighths cents per pound; and sugars exceeding twenty are taxed at two cents per pound. Molasses above fifty-six degrees is taxed at four cents per gallon. Sugar drainings and sweepings are subject to duty as either molasses or sugar, based on polariscopic tests. Coffee is taxed at three cents per pound, and tea at ten cents per pound. Various hides, including raw or uncurled hides and Angora goatskins, are taxed at one and one-half cents per pound. The plaintiffs argue that the section allowing the President to suspend provisions related to the free importation of sugars, molasses, coffee, tea, and hides is unconstitutional, claiming it delegates legislative and treaty-making powers to the President, thus rendering the entire act void. Conversely, the United States contends that such legislation is supported by historical precedent and the government's longstanding practices, asserting that even if the contested section is unconstitutional, the remaining provisions of the act should remain valid. The case of The Brig Aurora is referenced as precedent, highlighting the early legislative practice of delegating specific powers to the President in relation to trade restrictions based on foreign edicts. This practice continued with the act of 1809, which allowed the President to proclaim the revocation of trade restrictions contingent upon actions by France or Great Britain. Concerns were raised during this historical context about the transfer of legislative power to the President, but it was argued that Congress was merely defining the conditions for the law's revival based on factual determinations made by the President. Mr. Justice Johnson affirmed that the legislature has the authority to revive the act of March 1, 1809, either explicitly or conditionally, as it sees fit. The provision in the act stating its limited duration does not restrict Congress's power to extend its effects based on new circumstances. It is within Congress's competency to condition the act's revival on the President's proclamation, contingent upon the President's determination of changes in foreign edicts that would affect U.S. neutral commerce. This principle also applies to suspending the act based on similar presidential assessments. The excerpt highlights historical precedents where Congress has granted the President powers related to trade and commerce. Examples include legislation from 1794 allowing the President to impose embargoes when Congress was not in session and the 1798 act that suspended trade with France, contingent on specific conditions being met. Such historical practices lend significant weight to the current question of Congress's authority to delegate similar powers to the President based on the occurrence of specific events or facts as determined by him. On June 26, 1799, and May 2, 1800, proclamations were issued by the President, permitting U.S. vessels to enter specific ports in San Domingo. An April 18, 1866, Congressional act made it illegal to import certain goods from Great Britain and its colonies after November 15, 1806, including items made predominantly of leather, silk, hemp, and various other specified materials. This act was temporarily suspended by a December 19, 1806, act, allowing the President to further suspend it if deemed necessary, with a limit extending to the second Monday in December. Both acts were approved by President Jefferson. On March 3, 1815, President Madison approved legislation repealing discriminatory duties on tonnage and imports from foreign vessels whenever a foreign nation eliminated similar duties disadvantaging the U.S. Following this, President Monroe confirmed the abolition of such duties with proclamations from July 24, 1818, recognizing Bremen and subsequently issuing similar proclamations for Hamburg, Lubec, Norway, and Oldenburg. A March 3, 1817, act prohibited the importation of plaster of Paris from foreign vessels if the exporting nation had restrictions against U.S. vessels. This act was set to last five years, with a provision allowing the President to lift restrictions if the foreign nation ceased its prohibitions. Proclamations related to this act were also issued by President Monroe for trade with Nova Scotia and New Brunswick. An act concerning discriminating duties of tonnage and impost was approved in January 1824. Satisfactory evidence must be presented to the President of the United States by a foreign nation’s government confirming that no discriminatory duties on tonnage or impost are imposed on U.S. vessels or imported merchandise. Upon receiving such evidence, the President is authorized to issue a proclamation suspending these duties for that nation’s vessels and merchandise. This suspension takes effect upon notification and persists as long as reciprocal exemptions remain in place. Historical proclamations by various U.S. Presidents are documented, demonstrating the application of this authority from 1828 to 1880. A statute from May 31, 1830, repealed duties on foreign vessels contingent upon the abolition of countervailing duties by foreign nations disadvantaging the U.S. Additionally, a proclamation in 1855 allowed certain goods from Newfoundland to enter duty-free, following satisfactory evidence of compliance with a treaty. Furthermore, an act from March 6, 1866, prohibited the importation of cattle and their hides, with the Secretary of the Treasury authorized to suspend this prohibition for specific countries as determined. Public notice must be given that the importation of neat cattle and their hides will not introduce contagious or infectious diseases to U.S. cattle. The President can declare the act inoperative if he determines such importation poses no danger, effective 30 days after proclamation. These provisions were sections 2493 and 2494 of the Revised Statutes until the act of March 3, 1883, which changed their status. Furthermore, the 1890 tariff act prohibited the importation of neat cattle and hides but allowed the Secretary of the Treasury to suspend this prohibition if deemed safe. In line with Section 4228 of the Revised Statutes, President Arthur proclaimed that from March 1, 1884, products from Cuba and Puerto Rico would be exempt from discriminatory customs duties, with corresponding duties on goods from these territories under the Spanish flag suspended. However, President Cleveland later revoked this suspension on October 13, 1886, due to continued higher duties on U.S. goods compared to those carried by Spanish vessels. Additionally, the act of June 26, 1884, imposed tonnage duties on vessels from specific foreign regions and authorized the President to suspend excess duties based on foreign tax equivalencies. Presidents Arthur and Cleveland issued proclamations to suspend these duties for certain ports. Overall, the document outlines the legislative framework and executive actions regarding the importation of cattle and trade duties, reflecting the evolving trade policies and health concerns regarding livestock in the United States. The act of October 1, 1890, grants the President discretion in trade matters, reflecting a legislative trend in U.S. history aimed at protecting American interests against foreign regulations. Historical precedents demonstrate that Congress has frequently conferred similar powers to the President, asserting that such delegation is essential for national protection. Notable legislative examples include the President's authority to impose embargoes and modify trade restrictions based on public safety and national interest. The current act does not violate the constitutional principle against delegating legislative power to the President, as it does not grant him legislative authority but rather allows him to act on determinations made by Congress regarding reciprocal trade with specific countries. Congress has retained control over the conditions under which trade provisions may be suspended in response to foreign duties deemed unreasonable. Congress defined specific duties on sugar, molasses, coffee, tea, and hides produced or exported from designated countries during a suspension period. The President was mandated to ascertain whether these countries imposed unequal and unreasonable duties on U.S. products. Upon confirming such disparities, the President was required to issue a proclamation to suspend duties for that country, with discretion only regarding the duration of the suspension. This action did not equate to law-making; it was an execution of Congress's legislative will. The authority exercised by the President was to declare the occurrence of a specified event triggering the law, rather than creating law itself. The distinction lies in the fact that while legislative power cannot be delegated, the law can empower the President to determine factual conditions under which its provisions apply. Courts have recognized that many statutes depend on the discretion of designated individuals to activate them, but such discretion does not constitute law-making. Thus, a law can validly depend on future events without undermining legislative authority or effectiveness. Legislation effectiveness relies on information not accessible to lawmakers, necessitating external inquiry. The court finds no merit in claims that the third section of the October 1, 1890, act improperly transfers legislative and treaty-making authority to the President. Even if such a transfer occurred, it would not render other sections of the act, specifically those imposing duties on imports, ineffective. The act establishes a bounty for domestic sugar producers based on sugar quality, funded by unappropriated Treasury moneys. Appellants argue Congress lacks authority to allocate these funds, asserting that this provision's validity determines the entire act's constitutionality. However, the court counters that the act can remain partially valid, as constitutional sections can coexist with unconstitutional ones if independent. The court emphasizes that the duty provisions are not inherently linked to the bounty provisions, suggesting that the latter's invalidity would not invalidate the former. The act's primary objectives were to generate revenue for government support and to promote domestic manufacturing and industries, which were deemed crucial for national prosperity and safety. However, the provisions imposing duties on imported goods and those providing bounties for domestic sugar production are legally independent and separable. There is no evidence that the duties would not have been enacted without the bounties, nor does the act suggest that these provisions must operate together. Each part serves distinct purposes and should not invalidate the entire revenue statute if one provision is found to be invalid. Adopting a different approach could disrupt government financial operations and create significant confusion in the economy. The judgments from lower courts are affirmed without error.