Hayburn’s Case
Hayburn’s Case, decided in 1792, emerged from a law that mandated U.S. circuit court justices to hear disability claims from veterans and send their recommendations to the Secretary of War. This process led to significant controversy when five of the six justices refused to comply, arguing that the law infringed upon the principle of separation of powers by imposing nonjudicial responsibilities on them. They expressed concerns that Congress could choose not to abide by their judicial findings, thereby undermining the independence of the judiciary. The case is significant for scholars as it is seen as an early instance of the assertion of judicial review and the concept of justiciability, reflecting the justices' apprehensions about the implications of their rulings. In response to the controversy, Congress later revised the statute to address these legal complications. Hayburn's Case highlights the ongoing dialogue about the boundaries of judicial authority in the early years of the American legal system.
Hayburn’s Case
Date: 1792
Citation: 2 U.S. 409
Issues: Judicial review; judicial powers
Significance: In this early case, the Supreme Court asserted its power to find laws enacted by Congress unconstitutional and to decline to enforce them.
Congress passed a law in 1792 requiring the U.S. circuit court justices to hear veteran’s disability claims and forward recommendations to the secretary of war, who could decline to accept them. Five of the original six justices declined to do this, asserting in various ways that the law violated separation of powers by giving them nonjudicial duties in the executive branch. Some objected that Congress, rather than being bound by a judicial judgment, could decline to follow their findings. Congress later revised the law to avoid these difficulties. Although ambiguous, scholars regard this case as an early assertion of the Supreme Court’s powers of judicial review and justiciability because of concerns about the results of the justices’ deliberations.
