John Hessin Clarke

This case involved a U.S. Army Colonel discharged under § 24b of the Army Reorganization Act of 1920 after classification boards found he should not be retained in service. The officer petitioned for a writ of mandamus to vacate the discharge and restore his rank, arguing that lack of notice and hearing before certain boards violated due process under the Fifth Amendment. The Supreme Court of the District of Columbia granted the writ, but the Court of Appeals reversed, and the U.S. Supreme Court affirmed that reversal. The Court reasoned that Congress's plenary power over the military allows for administrative classification processes distinct from civil judicial procedures, that the officer received the required hearing before the Court of Inquiry, and that military tribunals acting within their jurisdiction provide due process that civilian courts cannot review or override.

federal powercivil rightsprocedure

The case concerned a dispute over priority rights to water diverted from the North Fork of the Republican River, an interstate stream, by a Nebraska irrigation company that had used a portion of the water in Colorado and the rest in Nebraska since 1890. Colorado state officials sought to enforce state laws declaring the water public property for Colorado's use only, potentially impairing the company's diversions based on later in-state appropriations. The District Court and Circuit Court of Appeals found federal jurisdiction based on both diversity of citizenship and a substantial federal question, then enjoined the officials from treating the company's rights differently due to the state line. The Supreme Court affirmed, ruling that the company's priority of appropriation for beneficial use across state lines was protected by the U.S. Constitution and could not be overridden by Colorado's in-state preference rules.

propertyenvironmentfederal power

This case involved a challenge by Southwestern Bell Telephone Company to a 1909 City of Houston ordinance setting local telephone rates, which the company argued were confiscatory and thus violated constitutional protections. The district court, after review by a master, found the rates produced insufficient revenue to cover operating expenses and enjoined their enforcement, using the fair value of the company's property at the time of inquiry as the rate-making base. The Supreme Court affirmed, holding that a 1915 merger ordinance purporting to limit rates to a return on capital actually invested was void under the Texas Constitution and did not bind the parties, so fair value rather than historical cost was the proper standard. The Court also declined to address certain valuation issues like going-concern value due to deficiencies in the record and briefs. The decree was affirmed without prejudice to future rate adjustments by the city.

business & regulatoryproperty

This case involved Colonel John W. French seeking a writ of mandamus to compel the Secretary of War to annul an order retiring him from active Army service under Section 24b of the 1920 Army Reorganization Act and to restore his prior status. The Supreme Court of the District of Columbia granted the writ, but the Court of Appeals reversed, and the Supreme Court affirmed that reversal after examining the statutory classification process. The Act establishes a multi-step system using preliminary classification boards, courts of inquiry, final classification boards, and an honest-and-faithful board, all subject to the President's supervisory authority, to reduce the Army while retaining fit officers. The Court held that the procedures were properly followed in this case, that the statute should be liberally construed to achieve its efficiency goals without technical restrictions, and that mandamus was not available to override the final classification.

federal powerprocedure

This case involved a suit by George Redeagle, a full-blood Quapaw Indian, seeking to have Paul A. Ewert declared to hold title to 100 acres of restricted Indian land in trust for him, on the ground that Ewert, while employed by the federal government in Indian affairs, had improperly acquired the land through an agent, Franklin M. Smith, in violation of Rev. Stats. § 2078. The District Court dismissed the petition, and the Circuit Court of Appeals affirmed the dismissal based on a later settlement stipulation between Ewert and Redeagle. The Supreme Court reversed, holding that the deeds from Redeagle to Smith, Smith to Ewert, and Redeagle to Ewert were all void because the statute barred Ewert from any interest in trade with Indians, and the settlement did not end the controversy since the land remained restricted at the time. The Court remanded with directions to cancel the deeds, order an accounting for rents, royalties, and profits, and address any mortgage liens on the property.

propertyfederal power

The case involved a dispute over freight rates for shipping two carloads of beer from San Francisco to Seattle in 1917, where the beer was packaged in thousands of individual cases addressed to separate persons. The railroad refused to accept the shipments in bulk carload lots for delivery to a transfer company, citing federal labeling requirements under the Criminal Code and state prohibition laws limiting imports to small quantities per person with special permits; it instead required individual billing and delivery. The steamship company sued to recover the higher less-than-carload rate, and the lower courts ruled in its favor. The Supreme Court affirmed, holding that the railroad could not lawfully transport the beer in carload lots to the named consignee because state law made each permit holder the ultimate consignee, required permits and markings on each package, and obligated the carrier to cancel permits upon delivery to individuals, making bulk delivery to a transfer company impermissible.

criminal lawbusiness & regulatoryfederal power

This case concerned the validity of a 1909 deed conveying restricted Quapaw Indian lands to Paul Ewert, a Special Assistant to the U.S. Attorney General tasked with prosecuting suits over Quapaw allotments. The Supreme Court held that Rev. Stat. § 2078, which bars persons employed in Indian affairs from any interest in trade with Indians, rendered the purchase void as to both adult and minor heirs. The Court reasoned that the statute's broad language covered Ewert's role and was intended to protect Indian wards from official self-dealing, making any such conveyance invalid regardless of administrative approval; it further held that equitable doctrines like laches could not validate a deed prohibited by statute. The decree was affirmed as to minor heirs and reversed as to adults, with remand for an accounting.

federal powerproperty

The case concerned whether the Pierce Oil Corporation, a Virginia company that built an intrastate pipeline in Oklahoma to supply its own refinery, could be compelled to continue transporting oil for the Phoenix Refining Company after refusing further service. The Oklahoma Corporation Commission ruled that Pierce qualified as a common carrier under state law and ordered it to carry Phoenix's oil to the extent capacity allowed, an order affirmed by the Oklahoma Supreme Court. The U.S. Supreme Court affirmed, holding that because Pierce had entered Oklahoma to do business years after the state constitution and statutes declaring such pipelines common carriers were in effect, it had voluntarily accepted those regulatory obligations as a condition of operating in the state. The Court concluded that this consent barred Pierce from claiming the order violated due process by taking its property, emphasizing the state's authority to set terms for foreign corporations engaged in wholly intrastate activities.

business & regulatoryproperty

The case involved a U.S. railway mail clerk injured in a train wreck on a line operated by the Director General of Railroads under the Federal Control Act. After receiving compensation under the Federal Employees’ Compensation Act, the petitioner sued the Director General for negligence, but the lower courts held that accepting the compensation barred the negligence action. The Supreme Court affirmed, reasoning that the Compensation Act provided a complete remedy against the United States for work-related injuries, with provisions showing Congress intended such payments to be full and final without further recovery or litigation for the same harm. The Court noted that both remedies targeted the same wrong by the government, and the Compensation Act's structure—offering prompt, no-fault awards—precluded pursuing the negligence remedy afterward.

federal powerlabor & employmenttorts & liability

In Collins v. McDonald, a habeas corpus petition was filed on behalf of a U.S. Army private convicted by court-martial of robbery in Vladivostok, Siberia, challenging the jurisdiction of the military tribunal on grounds that the specifications did not properly charge a federal crime. The District Court sustained a demurrer to the petition, and the Supreme Court affirmed on direct appeal. The Court reasoned that habeas corpus review is limited to whether the court-martial had jurisdiction over the person and offense, and the specifications sufficiently alleged robbery under the Articles of War and federal law by describing the taking of property by putting the victim in fear. Allegations regarding the sufficiency of evidence or confession were deemed not reviewable in habeas proceedings.

criminal lawprocedurefederal power

This case involved a shipment of horses from Nebraska to Washington under a through bill of lading that was damaged due to unwholesome food and water provided by an intermediate carrier. The shipper-consignee sued the terminal carrier for the injuries caused on the prior carrier's line. The Supreme Court held that the terminal carrier was not liable for the negligence of prior independent carriers. The core reasoning was that the Cummins Amendment modifies liability only for the initial carrier across the entire route, while common-law rules and the express contract terms limit each connecting carrier's responsibility to damage it actually caused on its own line, and the Blish case did not extend liability to the terminal carrier for earlier faults.

business & regulatoryfederal powertorts & liability

The case concerned an Illinois tax of $6,045 assessed on a West Virginia manufacturing corporation for the privilege of doing business in the state, calculated under a statute that averaged the percentage of the company's total business transacted in Illinois with the percentage of its tangible property located there. The company paid the tax under protest and sued to recover it, contending that including sales to out-of-state customers in the computation imposed a direct burden on interstate commerce in violation of the Federal Constitution. The Supreme Court upheld the assessment, concluding that the tax was not a regulation of or direct burden on interstate commerce but instead used interstate business only as one incidental factor among others (including in-state property and sales) to measure the capital stock represented by intrastate activity. The Court noted that the statute differentiated state from interstate business, applied equally to domestic and foreign corporations, taxed only property within the state, and produced an effect on interstate commerce that was remote rather than substantial.

taxesbusiness & regulatoryfederal power

The case concerned challenges to the constitutionality of New York’s 1920 Emergency Housing Laws, which modified landlord-tenant rules to let tenants in certain cities retain possession of dwellings until 1922 upon payment of court-determined reasonable rent and restricted eviction actions amid a housing shortage. The Supreme Court upheld the laws as constitutional. The Court reasoned that the statutes were a valid exercise of the state police power to address a grave social emergency, as shown by legislative investigations into shortages, rent profiteering, and resulting public harms, and that such measures did not impermissibly impair contracts since they were justified by the emergency; it followed precedents like Marcus Brown Holding Co. v. Feldman and Block v. Hirsh, finding the standards sufficiently definite under due process.

propertybusiness & regulatory

The case involved a property owner's claim for damages allegedly caused by the City of New York's construction of an elevated viaduct in the 1890s, which the courts determined constituted a change of street grade. After the New York Court of Appeals established the right to damages in 1917, the plaintiff filed a claim with the Board of Assessors, which awarded compensation; the 1918 amendment to the Greater New York Charter then made the Board of Revision of Assessments' confirmation of such awards final as to the amount of damages, limiting further judicial review to issues of jurisdiction, fraud, or willful misconduct. The plaintiff challenged the amendment's constitutionality, arguing it impaired contract rights, violated due process by restricting review of damage calculations, and denied equal protection due to the composition of the reviewing board. The U.S. Supreme Court affirmed the New York Court of Appeals, holding that the right to compensation was a vested property interest but not a contractual one under the Constitution, that the retained review mechanisms adequately protected due process, and that the board's makeup did not violate equal protection. The Court reasoned that eliminating general appellate review of honest errors in damage assessments did not offend federal constitutional guarantees.

propertyprocedure

The case involved a challenge to a fraud order issued by the Postmaster General under federal statutes, which barred delivery of mail and payment of money orders to the appellant, who sold 'Organo Tablets' advertised through the mail as a cure for various ailments including nervous weakness and sexual decline. The District Court denied an injunction and dismissed the bill, and the Circuit Court of Appeals affirmed. The Supreme Court affirmed, holding that the Postmaster General's determination—that the advertising constituted a fraud because the product was far from the panacea claimed—was a factual question committed to executive discretion and supported by substantial evidence, making it unreviewable by courts absent a showing that it was palpably wrong or arbitrary. A dissent argued that the statutes authorizing such orders violated the First Amendment by imposing prior restraints on speech.

business & regulatoryfree speechfederal power

This case concerned a boundary dispute between Georgia and South Carolina over the location of the line in the Savannah River and its tributaries, the Tugaloo and Chattooga rivers. Georgia argued for a midway line between the banks where no islands existed and claimed all islands, while South Carolina contended the line followed the low-water mark on the Georgia shore and disputed jurisdiction over Chattooga islands. The Supreme Court interpreted the 1787 Beaufort Convention, which reserved all islands in the Savannah and Tugaloo to Georgia and designated the most northern branch or stream as the boundary, to hold that the line runs midway between the banks (or island bank and South Carolina shore) at ordinary water stage. It further ruled that islands in the Chattooga River, as the northern extension of the Tugaloo, are reserved to Georgia. The decision resolved the controversy to facilitate taxation of dams and hydroelectric plants in the rivers.

propertyfederal power

The case involved the United States suing members of the American Hardwood Manufacturers' Association under the Sherman Antitrust Act of 1890, alleging that their voluntary "Open Competition Plan"—which involved centralized collection and dissemination of detailed price, production, sales, and inventory data among 365 participating mills—constituted a combination restraining interstate commerce in hardwood lumber. The District Court issued a permanent injunction limiting specified activities of the Plan, and the Supreme Court affirmed on direct appeal. The Court decided that the Plan violated the Act because its extensive information-sharing system, monthly meetings, and resulting uniformity in practices had the effect of restricting competition and stabilizing prices. The core reasoning was that the cooperation substituted knowledge of competitors' actions for independent market decisions, enabling members who produced one-third of U.S. hardwood output to narrow the market without any formal agreement on prices or output.

business & regulatory

The case involved a Tennessee corporation that owned cotton gins in Mississippi and challenged the state's 1914 Anti-Gin Act, which barred corporations involved in cotton seed oil or meal production from owning or operating cotton gins (with limited exceptions), on grounds that it unconstitutionally burdened interstate commerce and violated equal protection by applying only to corporations. The Mississippi courts upheld the law, imposed penalties, forfeited the company's right to do intrastate business, and ordered divestiture of the gins. The U.S. Supreme Court affirmed, holding that states have broad discretion to condition or exclude foreign corporations from doing local business and that the distinction between corporations and individuals was permissible under the police power to curb monopolistic practices, without imposing a direct burden on interstate commerce. The Court also found the classification reasonable and not arbitrary for equal protection purposes.

business & regulatoryfederal power

The case involved landowners in Drainage District No. 29 in Pocahontas County, Iowa, who challenged the constitutionality of a state statute permitting the county board of supervisors to assess the costs of repairing and cleaning existing drainage ditches without new notice or hearings, claiming this violated due process under the Fourteenth Amendment. The Supreme Court affirmed the Iowa Supreme Court's ruling that the statute and assessment were valid. The Court reasoned that the original drainage district proceedings had already lawfully determined the proportional benefits to each tract of land for the initial construction, so the repair assessment required only a ministerial calculation based on that prior proportion and did not constitute a new taking. It further held that determining the necessity and extent of repairs was an administrative detail of state taxation that did not require additional process, distinguishing this from cases involving new assessments or confiscation.

propertytaxesprocedure

This case involved a dispute over compensation for extra mail transportation services ordered by the Postmaster General under a contract between William Weighel and the United States for wagon mail service in Chicago. Weighel had subcontracted performance to Travis, who carried out both the original and additional services, but the Court of Claims dismissed Weighel's claim for extra pay on the ground that he had no interest in the services performed by Travis. The Supreme Court reversed, holding that the government maintained its contractual relationship solely with Weighel, who remained legally bound and entitled to payment, and that the extra service fell outside the contract's no-additional-compensation clause as interpreted in prior precedent.

business & regulatoryfederal power