Osborn v. Bank of the United States
Osborn v. Bank of the United States is a significant Supreme Court case decided in 1824, which further elaborates on the balance of powers between federal and state authorities. The case arose when Ralph Osborn, the Ohio state auditor, attempted to impose a tax on the Bank of the United States, a federal institution. Osborn's actions led to a federal court case after the bank contested the seizure of its assets. The Supreme Court, led by Chief Justice John Marshall, upheld the federal court's decision, emphasizing a broad interpretation of the Constitution's provision regarding federal jurisdiction. This ruling asserted that federal courts could hear cases related to federal questions, even if they had only a slight connection to federal law. Justice William Johnson dissented, expressing concern that this interpretation could lead to excessive federal jurisdiction. Ultimately, the case reinforced federal supremacy and judicial power in conflicts involving state actions against federal entities. This decision followed the earlier landmark case of McCulloch v. Maryland, emphasizing the growing complexity of federal-state relations in the early years of the United States.
Osborn v. Bank of the United States
Date: March 19, 1824
Citation: 22 U.S. 738
Issue: State taxation
Significance: The Supreme Court overturned a state tax on a federal corporation, affirming the constitutionality of the Bank of the United States.
Chief Justice John Marshall wrote the opinion for the 6-1 majority, using an elaborate defense of federal judicial power to uphold the Supreme Court’s decision in McCulloch v. Maryland (1819). As with McCulloch, this case involved a state (Ohio) opposed to the Bank of the United States that was attempting to impose a tax on a federal corporation. Ohio state auditor Ralph Osborn seized the assets of the bank but lost a countersuit in federal court. On appeal, the Court upheld the lower federal court, broadly interpreting the Constitution’s phrase “cases arising under” the Constitution, thereby claiming that any case involving the mere possibility of a federal question could be carried to the federal courts. Justice William Johnson dissented, saying he thought this decision gave federal courts jurisdiction over too many potential questions.
