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Chase Court
View on WikipediaThis article includes a list of references, related reading, or external links, but its sources remain unclear because it lacks inline citations. (July 2025) |
| Chase Court | |
|---|---|
| December 15, 1864 – May 7, 1873 (8 years, 143 days) | |
| Seat | Old Senate Chamber Washington, D.C. |
| No. of positions | 10 (1864-1866) 8 (1866-1869) 9 (1869-1873) |
| Chase Court decisions | |
The Chase Court refers to the Supreme Court of the United States from 1864 to 1873, when Salmon P. Chase served as the sixth Chief Justice of the United States. Chase succeeded Roger Taney as Chief Justice after the latter's death. Appointed by President Abraham Lincoln, Chase served as Chief Justice until his death, at which point Morrison Waite was nominated and confirmed as his successor.
The Chase Court presided over the end of the Civil War and much of the Reconstruction Era. Chase was a complete change from the pro-slavery Taney; one of his first acts as Chief Justice was to admit John Rock as the first African-American attorney to argue cases before the Supreme Court.[1]
During Chase's chief-justiceship, Congress passed the Habeas Corpus Act 1867, giving the Court the ability to issue writs of habeas corpus for defendants tried by state courts. The Chase Court interpreted the Fourteenth Amendment for the first time, and its narrow reading of the Amendment would be adopted by subsequent courts.[2] As Chief Justice, Chase presided over the 1868 impeachment trial of President Andrew Johnson. He also pursued the presidency twice while in office; he unsuccessfully sought the Democratic presidential nomination in 1868 and the Liberal Republican nomination in 1872.
Membership
[edit]The Chase Court began when President Abraham Lincoln appointed Salmon Chase to replace Chief Justice Roger Taney, who died in 1864. The Chase Court commenced with Chase and nine Associate Justices: James Moore Wayne, John Catron, Samuel Nelson, Robert Cooper Grier, Nathan Clifford, Noah Haynes Swayne, Samuel Freeman Miller, David Davis, Stephen Johnson Field.
During Chase's tenure, Congress passed two laws setting the size of the Supreme Court, partly to prevent President Johnson from appointing Supreme Court justices. The Judicial Circuits Act of 1866 provided for the elimination of three seats (to take effect as sitting justices left the court), which would reduce the size of the court from ten justices to seven. Catron died in 1865, and he had not been replaced when the Judicial Circuits Act was passed, so his seat was abolished upon passage of the act. Wayne died in 1867, leading to the abolition of his seat. However, Congress passed the Judiciary Act of 1869, setting the size of the court at nine justices and creating a new seat. In 1870, President Ulysses S. Grant appointed William Strong to replace Grier, and Joseph P. Bradley to fill the newly created seat. Bradley was nominated after the Senate rejected Grant's nomination of Ebenezer R. Hoar; the Senate had also confirmed Edwin Stanton's nomination for Grier's seat, but Stanton died before taking office. Nelson retired in 1872, and Grant appointed Ward Hunt to succeed him.
Timeline
[edit]
Note: + denotes new seat; − denotes abolished seat
Bar key:Other branches
[edit]Presidents during this court included Abraham Lincoln, Andrew Johnson, and Ulysses S. Grant. Congresses during this court included 38th through the 43rd United States Congresses.
Rulings of the Court
[edit]Notable rulings of the Chase Court include:
- Ex parte Milligan (1866): In an opinion written by Justice Davis, the court ruled that trials by military tribunal are constitutional only when the civil courts are not functioning, and there is no power left but the military. The case arose from an 1864 military tribunal in Indiana that tried several Union dissenters.
- Mississippi v. Johnson (1867): In an opinion written by Chief Justice Chase, the court rejected a Mississippi lawsuit seeking to force President Andrew Johnson to enforce Reconstruction laws. The court held that Johnson's decision to enforce such laws was discretionary.
- Crandall v. Nevada (1868): In an opinion written by Justice Miller, the court struck down a Nevada statute that imposed a $1 tax on people leaving the state. The court held that the right to travel is a fundamental right that cannot be impeded by states.
- Georgia v. Stanton (1868): In an opinion written by Justice Nelson, the court refused to intervene in the enforcement of the Reconstruction Acts, holding that the case constituted a non-justiciable political question.
- Texas v. White (1869): In an opinion written by Chief Justice Chase, the court held that the Constitution does not permit states to legally secede from the Union. The decision held that all acts of Confederate secession were legally null.
- Legal Tender Cases (1871): In a series of opinions, the court upheld the government's ability to print paper money under the Legal Tender Act.
- United States v. Klein (1871): In an opinion by Chief Justice Chase, the Court held that the principle of separation of powers prohibits Congress from prescribing a rule of decision for the federal courts to follow in particular pending cases.
- The Slaughter-House Cases (1873): In a 5–4 decision written by Justice Miller, the court held that the Fourteenth Amendment does not affect a state's police power. The decision would eventually be largely overruled by numerous Supreme Court decisions that incorporated the Bill of Rights to apply to state governments.
Gallery
[edit]References
[edit]- ^ "The Impeachment of Andrew Johnson: Salmon Portland Chase". Impeach-andrewjohnson.com. Retrieved December 11, 2011.
- ^ Lurie, Jonathan (2004). The Chase Court: Justices, Rulings, and Legacy. ABC-CLIO. pp. 87–89. ISBN 9781576078211. Retrieved 9 March 2016.
Further reading
[edit]- Abraham, Henry Julian (2008). Justices, Presidents, and Senators: A History of the U.S. Supreme Court Appointments from Washington to Bush II. Rowman & Littlefield. ISBN 9780742558953.
- Blue, Frederick J. (1987). Salmon P. Chase: A Life in Politics. Kent State University Press. ISBN 9780873383400.
- Cushman, Clare (2001). The Supreme Court Justices: Illustrated Biographies, 1789–1995 (2nd ed.). (Supreme Court Historical Society, Congressional Quarterly Books). ISBN 1-56802-126-7.
- Friedman, Leon; Israel, Fred L., eds. (1995). The Justices of the United States Supreme Court: Their Lives and Major Opinions. Chelsea House Publishers. ISBN 0-7910-1377-4.
- Goldstone, Lawrence (2011). Inherently Unequal: The Betrayal of Equal Rights by the Supreme Court, 1865-1903. Walker Books. ISBN 978-0802717924.
- Hall, Kermit L.; Ely, James W. Jr.; Grossman, Joel B., eds. (2005). The Oxford Companion to the Supreme Court of the United States (2nd ed.). Oxford University Press. ISBN 9780195176612.
- Hall, Kermit L.; Ely, James W. Jr., eds. (2009). The Oxford Guide to United States Supreme Court Decisions (2nd ed.). Oxford University Press. ISBN 978-0195379396.
- Hall, Timothy L. (2001). Supreme Court Justices: A Biographical Dictionary. Infobase Publishing. ISBN 9781438108179.
- Hoffer, Peter Charles; Hoffer, WilliamJames Hull; Hull, N. E. H. (2018). The Supreme Court: An Essential History (2nd ed.). University Press of Kansas. ISBN 978-0-7006-2681-6.
- Howard, John R. (1999). The Shifting Wind: The Supreme Court and Civil Rights from Reconstruction to Brown. SUNY Press. ISBN 9780791440896.
- Hyman, Harold M. (1997). The Reconstruction Justice of Salmon P. Chase In Re Turner and Texas v. White. University Press of Kansas. ISBN 978-0-7006-0835-5.
- Irons, Peter (2006). A People's History of the Supreme Court: The Men and Women Whose Cases and Decisions Have Shaped Our Constitution (Revised ed.). Penguin. ISBN 9781101503133.
- Kens, Paul (1997). Justice Stephen Field: Shaping Liberty from the Gold Rush to the Gilded Age. University Press of Kansas. ISBN 9780700608171.
- Labbé, Ronald M.; Lurie, Jonathan (2005). The Slaughterhouse Cases: Regulation, Reconstruction, and the Fourteenth Amendment. University of Kansas Press. ISBN 9780700614097.
- Lurie, Jonathan (2004). The Chase Court: Justices, Rulings, and Legacy. ABC-CLIO. ISBN 9781576078211.
- Martin, Fenton S.; Goehlert, Robert U. (1990). The U.S. Supreme Court: A Bibliography. Congressional Quarterly Books. ISBN 0-87187-554-3.
- McGinty, Brian (2009). Lincoln and the Court. Harvard University Press. ISBN 9780674040823.
- Niven, John (1995). Salmon P. Chase: A Biography. Oxford University Press. ISBN 9780199923304.
- Ross, Michael A. (2003). Justice of Shattered Dreams: Samuel Freeman Miller and the Supreme Court during the Civil War Era. LSU Press. ISBN 9780807129241.
- Schwarz, Bernard (1995). A History of the Supreme Court. Oxford University Press. ISBN 9780195093872.
- Tomlins, Christopher, ed. (2005). The United States Supreme Court: The Pursuit of Justice. Houghton Mifflin Harcourt. ISBN 978-0618329694.
- Urofsky, Melvin I. (1994). The Supreme Court Justices: A Biographical Dictionary. Garland Publishing. ISBN 0-8153-1176-1.
- White, Richard (2017). The Republic for Which It Stands: The United States During Reconstruction and the Gilded Age: 1865–1896. New York: Oxford University Press. ISBN 9780190619060.
Chase Court
View on GrokipediaBackground and Formation
Appointment of Salmon P. Chase
Chief Justice Roger B. Taney died on October 12, 1864, amid the ongoing Civil War, prompting President Abraham Lincoln to seek a successor who could ensure judicial support for Union policies.[8][9] On December 6, 1864, Lincoln nominated Salmon P. Chase, who had resigned as Secretary of the Treasury earlier that year after serving from March 1861 to June 1864.[10][5] In that role, Chase managed the Union's war financing, including authorizing the issuance of fiat currency known as greenbacks through the Legal Tender Act of 1862, which funded military expenditures without relying solely on taxation or bonds.[5] Chase's nomination represented a deliberate pivot from Taney's legacy, particularly his authorship of the 1857 Dred Scott decision affirming slavery's constitutionality, toward a chief justice aligned with antislavery principles and administrative expertise in wartime governance.[11] Lincoln viewed the appointment as carrying profound political weight, reinforcing the administration's legal foundation during the conflict and Reconstruction's onset.[12] The U.S. Senate confirmed Chase unanimously on December 6, 1864, the same day as the nomination, reflecting broad acknowledgment of his fiscal competence despite his prior intraparty challenge to Lincoln's 1864 presidential bid.[10][3] This swift, unopposed approval underscored the urgency for judicial stability and Chase's perceived reliability in upholding federal authority.[13]Historical Context of the Post-Civil War Era
The American Civil War concluded with General Robert E. Lee's surrender to General Ulysses S. Grant at Appomattox Court House on April 9, 1865, marking the effective end of major Confederate resistance and initiating the challenges of reintegrating the defeated Southern states into the Union.[14] This outcome prompted swift legislative action to address slavery's abolition, with Congress passing the Thirteenth Amendment on January 31, 1865, and achieving ratification on December 6, 1865, thereby prohibiting involuntary servitude except as punishment for crime.[15] Tensions arose immediately over readmission policies, as President Andrew Johnson's lenient approach—requiring Southern states to ratify the Thirteenth Amendment and repudiate secession debts—clashed with Radical Republicans in Congress, who insisted on stricter safeguards including new constitutions and protections for freedmen's rights before restoring representation.[16] Economic dislocations compounded these political frictions, as the Union's war financing through the Legal Tender Act of February 25, 1862—which authorized issuance of $150 million in non-interest-bearing "greenback" notes as legal tender—fueled inflation estimated at over 80% cumulatively by war's end, straining contracts, debts, and national credit while necessitating later congressional measures like income and excise taxes to stabilize prices.[17] The Fourteenth Amendment, proposed by Congress on June 13, 1866, and ratified on July 9, 1868, further escalated debates by defining citizenship, guaranteeing due process and equal protection against state abridgment, and penalizing former Confederate states for disenfranchising Black voters, effectively conditioning their full reintegration on compliance.[18] In the South, empirical patterns of violence hindered stable governance, with groups like the Ku Klux Klan—formed in Pulaski, Tennessee, in late 1865—engaging in targeted intimidation and murders against freedmen, Republican officials, and Unionists to suppress Black political participation and restore white supremacy, prompting federal responses such as the Enforcement Acts of 1870–1871. The Supreme Court's operational milieu shifted from the Taney era's doctrinal preference for states' rights and limited federal commerce power, as seen in decisions curtailing national authority, toward confronting expanded federal imperatives for enforcing emancipation, managing war-related detentions via habeas corpus petitions under the 1867 Act, and adjudicating fiscal legacies amid rising caseloads driven by Reconstruction disputes.[19][20] These dynamics created causal pressures between inherited judicial restraint favoring local sovereignty and congressional assertions of centralized power to secure Union victories' fruits, framing the Chase Court's early deliberations without predefined doctrinal resolution.Membership and Composition
Justices and Their Ideological Profiles
Salmon P. Chase, appointed Chief Justice on December 15, 1864, entered the Court with a background as an antislavery leader, Ohio governor from 1856 to 1860, U.S. Senator from 1849 to 1855, and Treasury Secretary from 1861 to 1864, where he established the national banking system and issued greenbacks to finance the Civil War.[21][22] His pre-appointment record emphasized opposition to slavery expansion, support for free labor principles, and fiscal innovation under exigency, but as Chief Justice, he demonstrated conservative leanings on property rights, dissenting in Hepburn v. Griswold (1870) against legal tender constitutionality beyond war necessities.[21] This profile balanced abolitionist roots with restraint against unchecked federal monetary power, influencing Court dynamics toward causal prioritization of constitutional limits over wartime precedents. The associate justices, numbering eight alongside the Chief during much of Chase's tenure, drew from Northern and border-state origins, with seven of nine hailing from free states pre-war, fostering leanings toward federal authority in Union preservation while varying on states' rights.[23] The Judiciary Act of 1866 reduced the Court's authorized size from ten to seven justices as vacancies occurred, nullifying President Andrew Johnson's nomination of Henry Stanbery and limiting Democratic appointments to maintain a Republican majority amid Reconstruction disputes.[24][25] This structural shift causally preserved ideological balance favoring antislavery and pro-Union perspectives, as two vacancies (James M. Wayne's death in 1867 and Robert C. Grier's retirement in 1870) reduced the bench without immediate replacements until President Grant's 1870 appointments elevated it to nine.[24] Key associates included antislavery Republicans like Noah H. Swayne, appointed in 1862 after relocating from Virginia to Ohio due to opposition to slavery, serving as U.S. Attorney and advocating Union causes, which aligned with expansive federal war powers.[26] Samuel F. Miller, appointed 1862 from Iowa, practiced medicine and law in frontier free states, embodying Republican commitment to national unity over local secessionist claims. David Davis, appointed 1862 from Illinois, managed Lincoln's presidential campaign and favored pragmatic federalism rooted in Whig precedents. In contrast, Stephen J. Field, appointed 1863 from California, advanced states' rights and economic liberty as a state supreme court justice, championing "free soil, free labor" constitutionalism against monopolistic restraints pre-appointment.[27] Democratic holdovers like Nathan Clifford, appointed 1858 from Maine, leaned toward strict constructionism and sympathy for Southern interests, providing counterweight to Republican majorities on federalism. Later appointees under Grant included William Strong, a Pennsylvania Republican congressman from 1863 to 1869 who supported Reconstruction measures pre-1870 appointment, reflecting initial pro-civil rights enforcement views shaped by wartime service.[1] Joseph P. Bradley, appointed 1870 from New Jersey, brought corporate law experience favoring contract sanctity and limited government intervention. Ward Hunt, appointed 1873 from New York, emphasized judicial restraint from his state court tenure. This composition, with Republican dominance from free-state backgrounds, tilted the Court toward upholding federal Reconstruction authority while accommodating economic conservatism from figures like Field and Chase.[23]
Timeline of Appointments and Departures
Salmon P. Chase was nominated by President Abraham Lincoln on December 6, 1864, and confirmed by the Senate the same day to succeed Chief Justice Roger B. Taney, who had died on October 12, 1864; Chase was sworn in on December 15, 1864.[28][4] The Court initially comprised ten members following expansions under prior administrations, but the Judiciary Act of July 23, 1866, mandated a reduction to seven seats by not filling the next three vacancies.[29]| Date | Event | Justice Involved | Details |
|---|---|---|---|
| May 30, 1865 | Death | John Catron (Associate) | Catron's death created the first vacancy under the 1866 act; the seat remained vacant for nearly five years amid political tensions during President Andrew Johnson's administration, including failed nominations such as that of Attorney General Henry Stanbery, who withdrew in 1866.[28][1] |
| July 5, 1867 | Death | James M. Wayne (Associate) | Wayne's death marked the second vacancy, further reducing active membership to eight total; no immediate replacement due to the reduction act and ongoing partisan conflicts.[28] |
| January 31, 1870 | Retirement | Robert C. Grier (Associate) | Grier, pressed by colleagues due to declining health, retired as the third vacancy, bringing the Court to seven members in line with the 1866 act; this seat lapsed without appointment during Chase's tenure.[28][30] |
| February 7, 1870 | Nomination | William Strong (Associate) | President Ulysses S. Grant nominated Strong, a Pennsylvania lawyer and former congressman, to fill Wayne's long-vacant seat.[31] |
| February 18, 1870 | Confirmation and Swearing-in | William Strong (Associate) | Senate confirmed Strong unanimously; he filled the fifth circuit seat, restoring membership amid Grant's efforts to bolster Republican influence post-Reconstruction disputes.[31] |
| February 7, 1870 | Nomination | Joseph P. Bradley (Associate) | Grant simultaneously nominated Bradley, a New Jersey lawyer known for corporate law expertise, for Catron's ninth circuit seat.[31] |
| March 21, 1870 | Confirmation | Joseph P. Bradley (Associate) | Senate confirmed Bradley after debate; sworn in March 23, 1870, increasing the Court to nine members despite the prior reduction intent.[31][1] |
| November 28, 1872 | Death | Samuel Nelson (Associate) | Nelson's death created a new vacancy in the second circuit seat, left unfilled until December 1873 under President Grant, after Chase's passing.[28] |
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