Fairchild v. Hughes | |
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Argued January 23 – January 24, 1922 Decided February 27, 1922 | |
Full case name | Oscar Leser, et al. v. Garnett et al. |
Citations | 258 U.S. 126 ( more ) 42 S. Ct. 274, 66 L. Ed. 499, 1922 U.S. LEXIS 2249 |
Court membership | |
| |
Case opinion | |
Majority | Brandeis, joined by unanimous |
Laws applied | |
Case or Controversy Clause, U.S. Const. Art. III |
Fairchild v. Hughes, 258 U.S. 126 (1922), was a case in which the Supreme Court of the United States held that a general citizen, in a state that already had women's suffrage, lacked standing to challenge the validity of the ratification of the Nineteenth Amendment. [1] A companion case, Leser v. Garnett , upheld the ratification. [2] [3] [4]
In 1919, the United States Congress proposed a Constitutional amendment reading: "Section 1: The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of sex." "Section 2: Congress shall have power to enforce this article by appropriate legislation." By July 1920, thirty-five states had ratified the proposal, with only one additional state needed for the Amendment to be adopted.
On July 7, 1920, Charles S. Fairchild challenged the validity of the ratification process for that Amendment in the Supreme Court of the District of Columbia. The challenge sought to prevent Secretary of State Charles Evans Hughes from officially declaring the Amendment valid. The district court dismissed the case on July 20, and Fairchild appealed to the Court of Appeals of the District of Columbia. On August 26, Hughes acknowledged Tennessee's ratification, and the Nineteenth Amendment to the United States Constitution became law. The Court of Appeals affirmed the lower court decision. The case was appealed to the Supreme Court. [3] [5] In November 1921, the Supreme Court agreed to hear the case, which was argued in January 1922. [6]
In February, the Court announced a unanimous decision authored by Associate Justice Louis Brandeis, concluding that Fairchild, as a private citizen, lacked standing to challenge the amendment's ratification under the limitations of the Case or Controversy Clause of Article III. [1] [6] On the same day, the Court also decided a companion case, Leser v. Garnett which upheld the Amendment's ratification process on the merits.
The Fairchild decision marked a departure from prior doctrine, which had allowed any citizen to sue to preserve a public right. [7]
This case is often seen as one of two cases, along with Frothingham v. Mellon , that became the genesis of the doctrine of legal standing. However, the term standing was not associated with Article III until the New Deal era. [8] [9]
The Constitution of the United States is the supreme law of the United States of America. It superseded the Articles of Confederation, the nation's first constitution, in 1789. Originally comprising seven articles, it delineates the national frame and constraints of government. The Constitution's first three articles embody the doctrine of the separation of powers, whereby the federal government is divided into three branches: the legislative, consisting of the bicameral Congress ; the executive, consisting of the president and subordinate officers ; and the judicial, consisting of the Supreme Court and other federal courts. Article IV, Article V, and Article VI embody concepts of federalism, describing the rights and responsibilities of state governments, the states in relationship to the federal government, and the shared process of constitutional amendment. Article VII establishes the procedure subsequently used by the 13 states to ratify it. The Constitution of the United States is the oldest and longest-standing written and codified national constitution in force in the world today.
The Nineteenth Amendment to the United States Constitution prohibits the United States and its states from denying the right to vote to citizens of the United States on the basis of sex, in effect recognizing the right of women to a vote. The amendment was the culmination of a decades-long movement for women's suffrage in the United States, at both the state and national levels, and was part of the worldwide movement towards women's suffrage and part of the wider women's rights movement. The first women's suffrage amendment was introduced in Congress in 1878. However, a suffrage amendment did not pass the House of Representatives until May 21, 1919, which was quickly followed by the Senate, on June 4, 1919. It was then submitted to the states for ratification, achieving the requisite 36 ratifications to secure adoption, and thereby go into effect, on August 18, 1920. The Nineteenth Amendment's adoption was certified on August 26, 1920.
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Civil liberties in the United States are certain unalienable rights retained by citizens of the United States under the Constitution of the United States, as interpreted and clarified by the Supreme Court of the United States and lower federal courts. Civil liberties are simply defined as individual legal and constitutional protections from entities more powerful than an individual, for example, parts of the government, other individuals, or corporations. The explicitly defined liberties make up the Bill of Rights, including freedom of speech, the right to bear arms, and the right to privacy. There are also many liberties of people not defined in the Constitution, as stated in the Ninth Amendment: The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people.
Hollingsworth v. Virginia, 3 U.S. 378 (1798), was a case in which the United States Supreme Court ruled early in America's history that the President of the United States has no formal role in the process of amending the United States Constitution and that the Eleventh Amendment was binding on cases already pending prior to its ratification.
Charles Stebbins Fairchild was an American businessman and politician who served as United States Secretary of the Treasury from 1887 to 1889 and Attorney General of New York from 1876 to 1877. He was a notable anti-suffragist, challenging the Nineteenth Amendment to the United States Constitution in 1920 and serving as president of the American Constitutional League.
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United States v. Moreland, 258 U.S. 433 (1922), was a case heard by the Supreme Court of the United States on March 9 and 10, 1922, and decided a month later on April 17. The case involved a Fifth Amendment rights issue centering on whether or not hard labor was an infamous punishment or whether imprisonment in a penitentiary was a necessity for punishment to be considered infamous.
Leser v. Garnett, 258 U.S. 130 (1922), was a case in which the Supreme Court of the United States held that the Nineteenth Amendment had been constitutionally established.
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Crowell v. Benson, 285 U.S. 22 (1932) is the landmark United States Supreme Court administrative law decision that outlined the adjudicatory authority of administrative agencies under Article III of the Constitution. The Court held that the United States Employees' Compensation Commission satisfied Fifth Amendment Due Process and the requirements of Article III with its court-like procedures and because it invests the final power of decision in Article III courts.
Ashwander v. Tennessee Valley Authority, 297 U.S. 288 (1936), was a United States Supreme Court case that provided the first elaboration of the doctrine of "Constitutional avoidance".
Bond v. United States, 564 U.S. 211 (2011), is a decision by the Supreme Court of the United States that individuals, just like states, may have standing to raise Tenth Amendment challenges to a federal law.
This timeline highlights milestones in women's suffrage in the United States, particularly the right of women to vote in elections at federal and state levels.
The Hughes Court refers to the Supreme Court of the United States from 1930 to 1941, when Charles Evans Hughes served as Chief Justice of the United States. Hughes succeeded William Howard Taft as Chief Justice after the latter's retirement, and Hughes served as Chief Justice until his retirement, at which point Harlan Stone was nominated and confirmed as Hughes's replacement. The Supreme Court moved from its former quarters at the United States Capitol to the newly constructed Supreme Court Building during Hughes's chief-justiceship.
The Taft Court refers to the Supreme Court of the United States from 1921 to 1930, when William Howard Taft served as Chief Justice of the United States. Taft succeeded Edward Douglass White as Chief Justice after the latter's death, and Taft served as Chief Justice until his resignation, at which point Charles Evans Hughes was nominated and confirmed as Taft's replacement. Taft was also the nation's 27th president (1909–13); he is the only person to serve as both President of the United States and Chief Justice.