Myers v. United States
"Myers v. United States" is a significant Supreme Court case from 1920 that addressed the scope of presidential authority over federal appointments. The case arose when President Woodrow Wilson dismissed Frank Myers, a postmaster in Oregon, before the expiration of his term, violating a 1916 statute that required Senate approval for such removals. Myers sought back pay through legal action, but the Supreme Court ultimately ruled against him in a 6-3 decision. Chief Justice William H. Taft, writing for the majority, affirmed the president's broad discretion to remove appointed officials in the executive branch, arguing that this power is essential for the effective execution of laws and is supported by the separation of powers doctrine. While this ruling established significant precedent for presidential removal authority, it was later tempered by the Court in "Humphrey's Executor v. United States" (1935), which clarified that this power does not extend to officials in independent regulatory agencies with quasi-legislative or quasi-judicial roles. The decision in "Myers v. United States" continues to influence discussions about the limits and responsibilities of presidential power in the United States.
Myers v. United States
Date: October 25, 1926
Citation: 272 U.S. 52
Issue: Presidential powers
Significance: The Supreme Court held that the president possessed an inherent power to remove members of the executive branch and that a law requiring senatorial approval was unconstitutional.
In 1920 President Woodrow Wilson fired Frank Myers, a postmaster in Oregon, before his term had expired. In so doing, Wilson ignored a 1916 statute requiring the Senate’s advice and consent before removing postmasters. Myers filed a suit for back pay. The Supreme Court, by a 6-3 margin, denied the claim. In a sweeping opinion for the majority, Chief Justice William H. Taft confirmed the president’s unqualified discretion to remove anyone that he had appointed to the executive branch. Because presidents had the constitutional responsibility to execute the laws faithfully, they must be able to exercise control over subordinates who act under their authority. Taft also argued that the president’s removal power was logically implied by the separation of powers doctrine. Three justices wrote vigorous dissents. Although the Myers precedent was never overturned, the Court in Humphrey’s Executor v. United States (1935) limited the precedent so that it does not apply to officials with quasi-legislative and quasi-judicial functions within the independent regulatory agencies.
