Quick Summary
William McCardle was denied a writ of habeas corpus after his arrest by federal officials. He appealed the rejection of his writ of habeas corpus to the Supreme Court. The Supreme Court has the ability to appeal and overturn decisions made by lower courts. However, while McCardle’s case was still pending in the Supreme Court, Congress passed a new law that repealed a portion of the 1867 law that allowed the Supreme Court to hear cases like these. President Andrew Johnson had vetoed the bill at first. However, Congress still went ahead and passed it anyway.
The issue presented to the Supreme Court was whether or not it could hear McCardle’s appeal under these circumstances. The Supreme Court found that it no longer had the jurisdiction to hear appeals because it had lost its appellate jurisdiction under the 1867 statute.
Facts of the Case
William McCardle (defendant), a newspaper editor in Mississippi, was arrested by federal government officials after he wrote a series of newspaper articles that were highly critical of the post-Civil War Reconstruction and resulting military rule of the South.
The federal government justified McCardle’s arrest because he violated several provisions of the Reconstruction Acts.
McCardle sought a writ of habeas corpus from a federal court in Mississippi but was denied. McCardle then sought appellate review of his habeas corpus petition in the United States Supreme Court, relying on an 1867 congressional statute that permitted the Supreme Court to have appellate jurisdiction over such matters.
However, while the case was pending in the Supreme Court, Congress passed a new law repealing the part of the 1867 statute that permitted Supreme Court appellate review of writs of habeas corpus. President Andrew Johnson vetoed this legislation, but Congress overrode his veto and reinstated its repeal of the 1867 statute.
I.R.A.C. Format
Issue
Did Supreme Court had the jurisdiction to rule a case under 1867 congressional statute?
Rule of Law
U.S. appellate courts in the United States have the authority to hear cases involving claims of federal constitutional rights violations, regardless of whether the level of government is at issue. As a result, the federal courts can examine state and municipal laws, procedures, and court judgments on appeals based on constitutional grounds, not only direct appeals of federal cases.
Reasoning and Analysis
The court had no jurisdiction over the appeal because, when Congress repealed several pieces of legislation that had established military courts, the court lost its authority to hear cases brought before those courts, which were now unconstitutional.
But, unfortunately, while the Supreme Court may review the constitutional power to divest jurisdiction, it is “not at liberty to probe into the motivations of the legislator,” as the Court puts it.
Thus, the court is unable to proceed with the case, for it has lost all jurisdiction over the appeal; and judicial duty is not less fitly performed by declining ungranted jurisdiction than by exercising firmly that which the Constitution and the laws confer.
Conclusion
The Supreme Court’s appellate jurisdiction does not originate from a statutory grant of authority. Instead, the court holds that the Constitution only grants authority “with such exceptions and under such limitations as Congress may enact.”
According to the Court, the jurisdictional repeal is legal since the Constitution authorizes it. Except for the effects on existing contracts, a repealed law must be treated as if it had never been enacted. After the legislation the action was filed and prosecuted under was repealed, the court could not rule in favor of either party.
Since the court no longer had jurisdiction over the appeal, it could not issue a ruling.
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