Samuel F. Miller
Samuel F. Miller was a prominent U.S. Supreme Court Justice, born in Kentucky as the eldest of eight children. Initially a physician, he transitioned to law and became politically active in Iowa, rising through the ranks of the Republican Party. In 1862, President Abraham Lincoln appointed him as an associate justice of the Supreme Court. Miller is notable for his strong support of the Union during the Civil War, evidenced by his decisions in significant cases like the Prize Cases, which upheld the Union's naval blockade, and Ex parte Garland, where he advocated for loyalty oaths for former Confederate officials.
Miller's judicial philosophy was characterized by a narrow interpretation of the Fourteenth Amendment, particularly highlighted in the Slaughterhouse Cases, where he argued against broad federal protections that could impede state authority. His views often clashed with those of Justice Stephen J. Field, who championed a more expansive interpretation of the amendment. Despite his initial influence, Miller's perspectives waned as the Court shifted and ultimately rejected his interpretations. Throughout his tenure, he was also known for his candid correspondence, particularly expressing frustration with colleagues who clung to their positions despite aging. Miller served on the Court until his death in 1890 at the age of seventy-four.
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Samuel F. Miller
Nominated by: Abraham Lincoln
Significance: Miller was one of the intellectual forces of the Supreme Court during the post-Civil War period. He wrote the first Court decision interpreting the breadth of the newly ratified Fourteenth Amendment.
Born in Kentucky, the oldest of eight children, Miller first practiced medicine. Dissatisfied with his life, he earned his law degree and moved to Iowa. Within a short time, he gained prominence and moved up through the Republican Party hierarchy. With the election of Abraham Lincoln to the presidency in 1860, Miller became a leading candidate to fill one of three Supreme Court vacancies. Lincoln appointed Miller associate justice in 1862.
Almost immediately, Miller exhibited his support for the Civil War by voting in the Prize Cases (1863) to uphold the Union navy’s blockade of Southern ports. After the war, he also favored loyalty oaths for former Confederate officials in Ex parte Garland (1867). He voted in the Legal Tender Cases (1870) to support the government’s decision to issue paper money to finance the war. Yet his most important opinion came in the Slaughterhouse Cases (1873). In these cases, Louisiana butchers claimed a state monopoly violated their constitutional rights to pursue the occupation of their choice. In his opinion, Miller explained that the Fourteenth Amendment was intended to protect the newly freed slaves. He disparaged the argument that the privileges and immunities clause extended federal constitutional protections to state citizens or that the due process clause protected an individual’s liberty to work at the occupation of his or her choice. Miller warned against using the Fourteenth Amendment to expand the federal courts’ powers over state legislatures, noting that such a decision would radically alter the relationship between the state and federal governments.
Miller continued to assert this narrow interpretation of the amendment throughout his career. His main opponent was Justice Stephen J. Field, who argued that the Fourteenth Amendment prohibited most state regulation of business. Miller was able to best Field in this argument in the Slaughterhouse Cases and Munn v. Illinois (1877), where the Court upheld state regulation of grain elevators. However, because of changes in Court personnel and Field’s dogged determination, Miller soon found himself outvoted. By the end of Miller’s career on the Court, his colleagues had rejected his narrow view of the Fourteenth Amendment.
In addition to his legal opinions, Miller was a frequent letter writer. The single thread running through Miller’s correspondence is his disgust with aging justices who were disabled but tenaciously hung onto office for fear of losing their salaries. Miller criticized his doddering colleagues and promised to retire upon reaching seventy. It was a promise he did not keep, remaining on the Court until 1890 when he died at the age of seventy-four.
Bibliography
Bader, William H., and Roy M. Mersky, eds. The First One Hundred Eight Justices. Buffalo, N.Y.: William S. Hein, 2004.
Ely, James W., Jr. The Fuller Court: Justices, Rulings, and Legacy. Santa Barbara, Calif.: ABC-Clio, 2003.
Fairman, Charles. Mr. Justice Miller and the Supreme Court. New York: Russell & Russell, 1939.
Friedman, Leon, and Fred Israel, eds. The Justices of the United States Supreme Court:Their Lives and Major Opinions. 5 vols. New York: Chelsea House, 1997.
Huebner, Timothy S. The Taney Court: Justices, Rulings, and Legacy. Santa Barbara, Calif.: ABC-Clio, 2003.
Lurie, Jonathan. The Chase Court: Justices, Rulings, and Legacy. Santa Barbara, Calif.: ABC-Clio, 2004.
Ross, Michael. Justice of Shattered Dreams: Samuel Freeman Miller and the Supreme Court During the Civil War Era. Baton Rouge: Louisiana State University Press, 2003.
Silver, David. Lincoln’s Supreme Court. Urbana: University of Illinois Press, 1956.
Stephenson, Donald Grier, Jr. The Waite Court: Justices, Rulings, and Legacy. Santa Barbara, Calif.: ABC-Clio, 2003.