Craig v. Missouri
Craig v. Missouri was a significant Supreme Court case that addressed the limits of state sovereignty concerning fiscal powers, specifically regarding the issuance of paper currency. The case arose when Missouri enacted a law permitting the circulation of loan certificates, which it argued were a legitimate exercise of its state authority. However, this action conflicted with Article I, Section 10 of the U.S. Constitution, which prohibits states from issuing "bills of credit." In a notable 4-3 decision, the Supreme Court, led by Chief Justice John Marshall, ruled against Missouri, declaring the law unconstitutional based on a historical analysis of paper money in the United States.
Marshall's opinion not only voided the Missouri statute but also supported the Judiciary Act of 1789, affirming the Court's authority in such matters. Dissenting opinions from Justices William Johnson, Smith Thompson, and John McLean suggested that the statutory language might provide an exception, indicating a divide in judicial interpretation. This case set a precedent for the limitations of state fiscal powers and foreshadowed future legal battles over similar issues, as evidenced in the later case of Briscoe v. Bank of the Commonwealth of Kentucky. Overall, Craig v. Missouri reflects ongoing tensions between state rights and federal constitutional authority in the realm of currency regulation.
Craig v. Missouri
Date: March 12, 1830
Citation: 29 U.S. 410
Issues: Fiscal and monetary powers; states’ rights
Significance: The Supreme Court’s split decision in a case involving loan certificates issued by the state of Missouri showed the beginning of the Court’s evolution away from the influence of Chief Justice John Marshall.
Article I, section 10, of the U.S. Constitution bans states from emitting “bills of credits.” Nonetheless, Missouri had authorized circulating loan certificates, arguing that they were a legitimate exercise of state sovereignty. The state further challenged the constitutionality of section 25 of the 1789 Judiciary Act. In a 4-3 split decision unusual for the Supreme Court at the time the Court overturned the Missouri law authorizing the certificates. In his opinion for the Court, Chief Justice John Marshall used a historical analysis of paper money in America to explain why the Constitution’s prohibition on state bills of credit voided the Missouri statute. In keeping with his Cohens v. Virginia (1821) opinion, Marshall also defended section 25 of the 1789 Judiciary Act, which granted nondiscretionary authority to the Court.
The three dissenters Justices William Johnson, Smith Thompson, and John McLean believed that there was enough variation in the statutory language to exempt the Missouri law from the constitutional provision. Seven years later, the new chief justice, Roger Brooke Taney, upheld a variant of the Missouri currency arrangement in Briscoe v. Bank of the Commonwealth of Kentucky (1837).