United States v. Klein
80 U.S. (13 Wall.) 128 (1872)
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
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Congress repealed the 1863 Statute.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
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
The US Supreme Court ruled
that the 1870 Statute was unconstitutional because Congress had exceeded
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.