Barron v. Baltimore
**Barron v. Baltimore Overview**
Barron v. Baltimore is a landmark Supreme Court case that addressed the relationship between the Bill of Rights and state governments. The case originated when John Barron, a business owner in Baltimore, sued the city after it altered the waterfront, severely impacting his property without just compensation, which he argued violated his Fifth Amendment rights. The central issue was whether the protections of the Bill of Rights applied to state actions or were limited to the federal government only. The Supreme Court ruled that the Fifth Amendment did not extend to state governments, thus denying Barron his claim for protections against state action. This ruling established a precedent that the Bill of Rights was primarily aimed at the federal government, a stance that persisted for several decades. Although the subsequent Fourteenth Amendment appeared to challenge this ruling, the Court initially upheld Barron, maintaining its principles until the 1920s, when a gradual shift occurred leading to the incorporation doctrine. This doctrine would eventually extend certain protections within the Bill of Rights to include state actions, effectively altering the implications of the original Barron decision over time.
Barron v. Baltimore
Date: February 16, 1833
Citation: 32 U.S. 243
Issues: Incorporation doctrine; property rights
Significance: The Supreme Court held that the Bill of Rights did not protect citizens from actions by their state governments, a ruling that stood largely unaltered until the 1920’s.
The First Amendment begins with the word “Congress,” apparently making the federal government its only target, but none of the other amendments in the Bill of Rights include this language. John Barron, a Baltimore businessperson, sought to test the possibility that the Fifth Amendment in the Bill of Rights might protect him from actions of the Maryland state government.
The city of Baltimore repaired the streets and dumped the leftover construction materials into the water near the wharf Barron owned, raising the bottom of the bay so much that ships could no longer dock there, depriving Barron of his property interest in his livelihood without due process or just compensation. Barron sued Baltimore to recover damages, but Baltimore was a subunit of Maryland, whose constitution, unlike the U.S. Constitution, did not provide a guarantee against eminent domain.
Because Barron could not succeed in Maryland courts, he turned to the federal courts. However, the Supreme Court ruled that the Fifth Amendment applied only to the federal government and not to the states and that therefore Barron was not entitled to protection against state action under this amendment. After Barron, the courts applied this ruling consistently. Although the passage of the Fourteenth Amendment would seem to have reversed this decision, the Court did not initially agree, essentially continuing Barron in force until justices holding different views began to serve on the Court in the 1920’s. Gradually, the incorporation doctrine effectively overturned the principles set out in Barron.