United States v. Klein

1871

Venue: SCOTUS

Facts: Wilson had some cotton, which was forfeited duting the Civil War. You could get your forfeited stuff back by proving your ownership of it, and taking an oath that you provided no aid to the rebellion. The president possessed the power to pardon rebels, and Wilson was pardoned. Klein was the administrator of the estate, and he wants some money for that cotton. In the meantime, Congress passes an act saying that a pardon isn't admissible as evidence to establish a claimant's right to property, and in fact the existence of a pardon proves that you DID give aid to the rebellion, and if there is a pardon, the court would lose its jurisdiction and dismissal would follow.

Posture: The court of claims gives Klein $125K for the cotton, and the Attorney General moves to dismiss for want of jurisdiction.

Issue: Can congress tell the court how to interpret the law (i.e., the meaning of a pardon?)

Holding: No. Affirmed.

Rule: The legislature can't change the effect of a pardon any more than the executive can change a law.

Reasoning: In Padelford we said that a pardon means you were loyal, because your disloyalty is thereby wiped out. By this act, Congress is treading on the judicial power (i.e., the court gets to say what the law is). Congress can't forbid the court from giving the effect to evidence that the court thinks it should have.

Dicta: Congress can't withold appellate jurisdiction merely "as a means to an end" (i.e., as an end-run around separation of powers with either the executive or the judiciary).