Muskrat v. United States
Muskrat v. United States is a significant Supreme Court case that addresses the principle of judicial authority in the context of advisory opinions. The case arose when Congress enacted legislation impacting Native American affairs and sought clarification on its constitutionality. In a unique legal maneuver, the government arranged for a lawsuit that involved nominal parties, with the U.S. government represented by the attorney general and Native Americans through counsel funded by the Treasury. This situation raised questions about the genuine nature of the dispute, as the Court has historically maintained that it will only adjudicate actual conflicts between parties. In a unanimous ruling, the Supreme Court, with Justice William R. Day delivering the opinion, determined that it lacked jurisdiction to hear the case, reinforcing the idea that courts do not issue advisory opinions. This decision highlights the importance of the case-and-controversy requirement in maintaining the integrity of the judicial process. Muskrat v. United States serves as a foundational example of the limitations placed on the judiciary regarding non-justiciable matters.
Muskrat v. United States
Date: January 23, 1911
Citation: 219 U.S. 346
Issue: Cases and controversies
Significance: The Supreme Court maintained that the federal courts will hear only genuine cases and controversies and will not give advisory opinions.
Very early in its history, the Supreme Court decided that the fundamental principle that courts should hear only genuine conflicts between parties (or cases and controversies) meant that the Court could not give advisory opinions. Muskrat v. United States is an almost classic attempt to bring a mock case or a friendly lawsuit between parties before the Supreme Court for the purpose of getting an advisory opinion. Congress had passed legislation affecting Native Americans and sought to discover whether it was constitutional. Congress specified that the U.S. government would be represented by the attorney general and that the Native Americans would be represented by counsel paid for by the U.S. Treasury. The Court, down to seven members because Justices Willis Van Devanter and Lucius Q. C. Lamar did not participate, rendered a unanimous decision denying the Court’s jurisdiction; the opinion was written by Justice William R. Day.
