Muskrat v. United States

219 U. S. 346
Decided Supreme Court of the United States
Disposition
Decided
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Court
Court of Claims
Decided
Judge
Mr. Justice Day
Posture
The Court of Claims ruled on the merits of the constitutionality of the Acts of 1906.
Plaintiffs/Appellantss (4)
David Muskrat, J. Henry Dick, William Brown, and Levi B. Gritts
v.
Defendant/Appellee (1)
United States

Overview

The judgment of the Court of Claims is reversed, and the case is remanded with directions to dismiss the petition for want of jurisdiction.

Case summary

Muskrat v. United States is a foundational case in American constitutional law establishing the principle that the federal judiciary cannot issue advisory opinions. The plaintiffs sought to challenge the constitutionality of Congressional acts that expanded the class of Cherokee citizens eligible for land allotments. The Supreme Court reversed the Court of Claims, holding that because the suit was brought under a special act of Congress merely to test the validity of legislation rather than to resolve a genuine dispute between adverse parties, it did not constitute a 'case' or 'controversy' under Article III of the Constitution.

Abstract

The case established that the federal judiciary cannot issue advisory opinions, as the suit was brought under a special act of Congress to test legislation's validity without a genuine dispute between adverse parties. The Supreme Court held this did not constitute a 'case' or 'controversy' under the Constitution. The judgment was reversed, and the case remanded to dismiss for lack of jurisdiction.

Jurisdiction

challenged
Jurisdictional holding
The Supreme Court held that the lower court lacked jurisdiction because the suit did not present a 'case' or 'controversy' within the meaning of Article III of the Constitution.

Procedural posture

Posture at trial
The Court of Claims ruled on the merits of the constitutionality of the Acts of 1906.
Posture on appeal
Direct appeal to the Supreme Court.

Legal categories

Criminal

Case record

Docket number
219 U. S. 346
Court
Supreme Court of the United States
Trial court
Court of Claims
Decided
Opinion author
Mr. Justice Day
Opinion type
published
Precedential status
binding
Judges on panel
Day

Issues & holdings

1
Issues raised
1
reversed
1
Holdings
Standard of review

de novo

Disposition rationale

The Court held that Congress cannot authorize the judiciary to render advisory opinions on the constitutionality of legislation outside of a concrete case or controversy.

Holdings of the court

Justiciability of the suit
The suit is not a 'case' or 'controversy' under Article III.
The judicial power of the United States is limited to cases and controversies. A suit brought solely to test the constitutionality of an act of Congress, without a concrete dispute between adverse parties, is an attempt to obtain an advisory opinion, which the Court lacks the power to provide.
non-binding

Timeline

No timeline recorded.

Facts & evidence

Key facts

3 facts
  1. The Act of July 1, 1902, provided for the allotment of Cherokee lands and funds to individuals living on September 1, 1902.
  2. Subsequent Acts of April 26, 1906, and June 21, 1906, authorized the enrollment of Cherokee children born after September 1, 1902, to participate in the distribution of unallotted lands and funds.
  3. Plaintiffs sought a judicial declaration that the 1906 Acts were unconstitutional as they allegedly impaired vested rights of those enrolled under the 1902 Act.

Authorities

No authorities recorded.

Index terms21
Summary terms
Legal concepts
Legal issues
Search facets
Parties
Judges
Day
Courts
Other recorded fields

Legal actions

Action type
reversed
Target
Court of Claims judgment
Context
The Supreme Court reversed the lower court's decision on the merits because the lower court lacked jurisdiction to hear the case.
Scope
full