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Decision levers
AI-measured from their own opinions — each lever cites its cases
Willing to revisit precedentStrong stare decisis
Explicitly follows prior jurisdictional rulings rather than deciding anew, citing established precedent as binding [4]. Jackson v. Ashton ↗
Judicial activismJudicial restraint
Dismisses for strict compliance with pleading rules and remands to conform to higher authority rather than expanding judicial reach [4][5]. Jackson v. Ashton ↗ Davis v. Packard ↗
Deference to government powerSkepticism of government power
Enforces federal exclusivity and consular immunity against state-court assertions of power while scrutinizing executive land grants for formal compliance [5][6]. Davis v. Packard ↗ United States v. Richard ↗
Affiliations
Supreme Court of the United States — appointed by John Adams
This case involved a replevin action in which the plaintiff sought to recover goods distrained for allegedly unpaid rent arising from a deed granting an annuity or rent charge of $500 per year on property in Alexandria in exchange for $5,000. The plaintiff claimed the underlying contract was usurious and offered evidence including a witness, Jonathan Scholfield, who had executed the original deed and later assigned interests in the property. The circuit court admitted the witness and gave jury instructions on determining usury from all circumstances of the transaction. The Supreme Court held that Scholfield was incompetent to testify due to his ongoing financial interest in the outcome, as shown by conditional releases and indemnification agreements, and therefore reversed the judgment and remanded for a new trial. The Court found no error in the circuit court's refusal to give certain separate instructions on usury or in its overall instructions leaving the loan-versus-annuity question to the jury based on the full facts.
The case involved a New York insurance company's efforts to enforce a mortgage and promissory notes on a Louisiana plantation and slaves through a confessed judgment in federal district court. After an initial order of seizure was enjoined and the parties reached a notarized transaction for judgment and delayed execution, the district judge died before signing the judgment; his successor declined to complete it without further notice to the defendant. The Supreme Court denied the petition for a writ of mandamus directing the district judge to enter the specific judgment sought. The Court reasoned that the district judge had not refused to render any judgment and that the petition did not specifically request an order merely to proceed to judgment, making the requested relief inappropriate on the facts presented.
In Delassus v. United States, the petitioner claimed title to a square league of land in Missouri based on a 1795 Spanish concession granted by the lieutenant governor of Upper Louisiana under orders from the governor-general, for the purpose of lead mining, which was protected by the 1803 Louisiana Purchase treaty and pursued under the 1824 federal statute authorizing suits to validate such claims. The district court had ruled the claim invalid, but the Supreme Court reversed, declaring the title valid and confirming it according to the 1799 survey. The core reasoning was that the concession was legally made by the proper Spanish authorities, who held full power not constrained by subordinate regulations such as O'Reilly's, the 1824 act applied to all qualifying French or Spanish grants without any reservation for lead mines, and the grant could have been perfected into complete title under Spanish laws and customs absent the transfer of sovereignty.
The case involved the heirs of Auguste Chouteau petitioning for confirmation of title to 1,281 arpents of land near St. Louis, based on a 1800 concession from the lieutenant governor of upper Louisiana for firewood to support a distillery, with an order of survey executed in 1801. The Supreme Court reversed the district court's denial and confirmed the claim, holding that the lieutenant governor possessed authority as sub-delegate to issue the order of survey despite the 1799 transfer of land-granting power to the intendant-general. The Court reasoned that the order constituted a valid foundation of title under acts of Congress, capable of being perfected and treated as property, with possession maintained since the grant. All principles from prior similar cases applied, leading to full confirmation of the boundaries as surveyed.
This case concerned a claim by the heirs of Auguste Chouteau to confirm a land concession of one league square granted by Spanish authorities in upper Louisiana in 1798. The district court had rejected the claim, but the Supreme Court reversed that decision and confirmed the title. The Court reasoned that the lieutenant governor had certified the applicant's eligibility under the applicable regulations, which may have been adapted for the region, and that proof of property qualifications like cattle ownership was a matter for the granting officer rather than reexamination by the court. It also found that a subsequent grant did not invalidate the earlier one, as the later concession was rejected and could not affect the prior valid claim.
The case involved a dispute over title to a lot in New Orleans, where private claimants held an incomplete Spanish-era grant that was later confirmed by a U.S. patent, while the city asserted the land formed part of a public quay under the original town plan and could not be privately granted. State courts ruled in favor of the claimants in a petitory action. The U.S. Supreme Court dismissed the city's writ of error, holding that it lacked jurisdiction under the 25th section of the Judiciary Act because neither the Louisiana cession treaty nor the act admitting Louisiana to the Union created a federal question that survived statehood or allowed review of state-court decisions on pre-cession land titles. The Court reasoned that the treaty's property protections ended upon Louisiana's admission to the Union on equal footing, the federal patent did not purport to extinguish prior titles, and the underlying controversy turned solely on French and Spanish law.
