Constitutional Law I, Pages 67–68

United States v. Klein

1872

Facts:

Klein, the administrator of Wilson's estate, applied for compensation for property seized by the government during the Civil War. Only those that remained loyal were eligible for compensation however. Wilson had fought for the Confederacy, but accepted President Johnson's amnesty and pardon afterwards. Case precedence held that amnesty recipients were conclusively deemed to be loyal despite any contrary facts.

While Klein's appeal for the compensation was pending, Congress enacted legislation stripping the federal courts of jurisdiction over compensation cases based on amnesty and that receipt of amnesty was "conclusive evidence" of disloyalty instead and required the case to be dismissed.

Issue:

Was Congress's legislation a valid limitation of appellate authority?

Reasoning:

While simply denying jurisdiction in a class of cases, such an act would be within Congress's power. However, this act goes much farther than this. It also declares that pardons shall not be considered on appeal, contrary to court precedence; that the Supreme Court lacks jurisdiction on appeal for such cases based solely on amnesty, and should thus dismiss them; and that accepting amnesty is conclusive evidence of the act recited.

This requires Congress to have jurisdiction insofar as to hear certain facts such as the acceptance of amnesty or other defenses. After the basis is determined, then the Supreme Court is supposed to dismiss it for want of jurisdiction. This just seems like a tricky way to try to force the Supreme Court to rule a certain way however, not a valid exception to its appellate power.

Holding:

No, Congress's restriction of jurisdiction here was invalid.