United States v. Klein
80 U.S. 128 (1871)

  • President Lincoln issued a proclamation offering a pardon to any person who had supported or fought for the South, with full restoration of property rights, subject only to taking an oath of allegiance.
    • Congress had passed a Statute in 1863 that permitted an owner of property confiscated during the war to receive the proceeds from the sale of the confiscated property.
  • Based on the 1863 Statute and the President’s proclamation, Wilson took the oath of allegiance and honored it until his death in 1865. Klein, the administrator of Wilson’s estate, then applied, to the Court of Claims to recover the proceeds of the sale of property seized from Wilson.
    • While the case was pending, Congress repealed the 1863 Statute.
  • The Court of Claims, found that Wilson’s estate was entitled to the proceeds from the sale of his property.
  • In 1870, after Wilson’s case was settled, Congress passed a new law that basically reversed what the 1863 Statute said.
    • This 1870 Statute prohibited the use of Lincoln’s Presidential pardon as the basis for claiming sale proceeds, and further said that acceptance of such a pardon was evidence that the person pardoned did provide support to the South and was ineligible to recover sale proceeds.
  • Armed with the 1870 Statute, the US appealed to the Supreme Court.
    • The US argued that based on the 1870 Statute, since Wilson had accepted a Presidential pardon his estate was not entitled to the sale proceeds.
  • The US Supreme Court found for Wilson’s estate.
    • The US Supreme Court ruled that the 1870 Statute was unconstitutional because Congress had exceeded its power.
      • The Court found that the 1870 Statute was an unconstitutional infringement on the judicial branch because it prescribing the rule of decision in a particular cause.
    • The Court also ruled that Congress had impermissibly infringed the power of the executive branch by limiting the effect of a Presidential pardon.
  • Basically, in this case the US Supreme Court said that one branch of government may not impair the powers of another (aka separation of powers).
    • In this case, that means that Congress can’t impair the power of a Presidential pardon, or stop a court from deciding the law.