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Ex parte Siebold

From Wikipedia, the free encyclopedia

1879 United States Supreme Court case
Ex parte Siebold
Decided October 1, 1879
Full case nameEx parte Siebold
Citations100U.S.371 (more)
Holding
So long as the vesting is consistent with theseparation of powers, Congress has discretion to vest the appointment of aninferior officer in the President, a Department Head, or a Court of Law.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Nathan Clifford · Noah H. Swayne
Samuel F. Miller · Stephen J. Field
William Strong · Joseph P. Bradley
Ward Hunt · John M. Harlan
Case opinions
MajorityBradley, joined by Waite, Swayne, Miller, Strong, Hunt, and Harlan
DissentField, joined by Clifford
Laws applied
U.S. Const. art. II, § 2, cl. 2

Ex parte Siebold,100 U.S.371 (1879), was aUnited States Supreme Court case concerning theseparation of powers and theAppointments Clause.

Background

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Baltimore election officials were indicted under theEnforcement Act of 1870 for stuffing ballot boxes and destroying the votes of African Americans in a congressional election. In defense, they contested Congress' authority under the Appointments Clause to control their work as state officials.[1]

Decision

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Writing for the majority, Associate JusticeJoseph P. Bradley rejected the officials' claim to independence from federal oversight of their federal elections. Opining that theFifteenth Amendment to the United States Constitution authorized the Enforcement Act of 1870, he upheld the act.[1]

Legacy

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TheHarvard Law Review has deemed this case as an exception to theanti-commandeering doctrine expressed inPrintz v. United States (1997), reasoning that it allows the federal government to control state officials and their resources in pursuance of itsElections Clause authority.[2]

References

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  1. ^abFoner, Eric (2019).The Second Founding: How the Civil War and Reconstruction Remade the Constitution.W. W. Norton & Company. p. 148.ISBN 9780393652574.
  2. ^"H.R. 1, 116th Cong. (2019)".Harvard Law Review.133:1806–1813. March 2020.

External links

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EnglishWikisource has original text related to this article:
Appointment of Officers
Officers vs. Employees
Inferior Officers
Recess Appointments
Challenges to Appointments
Appointments by Congress
Removal of Officers
Limits on Removal Power
Removal by Congress
Jurisdiction stripping
Ratification
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