Ex Parte Siebold
Ex Parte Siebold is a significant Supreme Court case that addressed the responsibilities of state officials in federal elections. The case arose from the conviction of a Baltimore election official who was found guilty of ballot box stuffing, a violation under the Enforcement Act of 1870. This act was established to ensure that state officials fulfilled their duties during federal elections. The court's majority opinion emphasized that, since the election in question was for a federal congressional seat, the federal government had the authority to impose duties on state officials. The ruling clarified that violations of mixed federal-state duties could lead to federal prosecution, thereby underscoring the federal government's role in overseeing electoral integrity. Dissenting opinions, particularly from Justices Stephen J. Field and Nathan Clifford, argued against the federal imposition of duties on state officials. Ultimately, Ex Parte Siebold highlighted the intersection of state and federal responsibilities in the electoral process, especially within the context of the Fifteenth Amendment.
Ex Parte Siebold
Date: March 8, 1880
Citation: 100 U.S. 371
Issues: Fifteenth Amendment; right to vote
Significance: The Supreme Court broadly read the federal government’s power when it determined that the federal government could punish a state official for mixed federal-state duties.
Justice Joseph P. Bradley wrote the opinion for the 7-2 majority, upholding the conviction of a Baltimore election official under the 1870 Enforcement Act for stuffing ballot boxes. The act made it illegal for state officials to fail to perform their duties under state or federal law in a federal election. The official argued that he could not be convicted for federal offenses because he was a state official on whom a federal duty could not be imposed. However, noting that this election was for a federal congressional seat, the Supreme Court held that a violation of a mixed federal-state duty was an offense against the federal government for which he could be punished. The Court limited the scope of the 1870 act to federal elections only. Justices Stephen J. Field and Nathan Clifford dissented, but it was Justice Field who asserted that the federal government did not have the right to mandate duties for a state official.
