| United States v. Adams | |
|---|---|
 | |
| Original jurisdiction Argued August 8, 1807 Decided April 21, 1808 | |
| Full case name | United States v. John Quincy Adams, United States Senator of Massachusetts |
| Decision | [Marshall Opinion] |
| Questions presented | |
| Does Article II Section 4 of the United States Constitution prohibit a member public endorsing the impeachment of an elected or appointed official who is outside the branch of government of the campaigner in question? | |
| Outcome | |
| Public endorsement of Impeachment of public officials is ruled as protected speech under the First Amendment of the United States Constitution. Article II Section 4 of the United States Constitution does not prohibit public endorsement of an elected or appointed official | |
| Court membership | |
| |
| Case opinions | |
| Majority | John Marshall, William Cushing, Samuel Chase, Bushrod Washington, Brockholst Livingston, Thomas Todd, joined by William Johnson |
| Concurrence | William Johnson |
United States v. Adams edit
United States v. Adams was a landmark decision of the United States Supreme Court that affirmed the rights of non executive, legislative, or judicial citizens to publically call for the impeachement of an elected or appointed official. This changed the view of the Impeachment Process by many people across the country, going from a technical bureaucratic process to a political process. Decided in 1808, United States v. Adams is regarded as one of the most important decisions in American Constitutional Law concerning the First Amendment. The Marshall Court upheld the legitimacy of the First Amendment as it applies to the Federal Government.
Background edit
Following the Chesapeake–Leopard affair, and the death of 3 United States sailors, Senator John Quincy Adams publically called for the resignation or impeachment of President Thomas Jefferson. This call for impeachment represented a significant incerase in tensions of the New England Secession Crisis. Adams' call for impeachment was considered highly political and did not recieve much support in Congress. Adams did however gain much prominence across New England and would become the Federalist Party nominee for the 1808 United States Presidential Election.
Many in the Capitol, including President Jefferson, did not believe that Adams had legal jurisdiction to call for the impeachment of President Jefferson. Impeachment was only considered a theoretical process at the time, meant to be carried out by bureaucrats within the same branch as the official under the impeachment inquiry. Many believed that impeachment proceedings were not even meant to be made public. The United States Government, under the direction of Thomas Jefferson, filed a petition to be heard in the United States District Court for the District of Columbia, alleging that the process of impeachment was a private executive affair and was protected by executive privilege under Article II Section 3 of the United States Constiution. The original case in the United States District Court for the District of Columbia was originally decided in favor of the United States government as the court was composed primarily of Jefferson appointees. The court originally held that pending investigations are protected under executive privilege and that a proposal of an investigation into a branch of government constitutes a pending investigation and any substantive speech on the subject is forbiden. This decision was heavily unpopular with both the Democratic-Republicans and Federalists in Congress. The Democratic-Republicans believed this gave too much power to the federal government to regulate the speech of the people. The Federalists were more likely to agree with the decision on ideological grounds, but were upset that Jefferson had won the case, believing the decision to be largely a political one. Adams quickly filed a writ of certiorari requesting that the Supreme Court hear the case, bypassing the United States Court of Appeals for the District of Columbia Circuit. The Supreme Court agreed to hear the case on June 21st, 1807 and quickly issued a preliminary injunction against the United States, allowing Adams to continue his public calls for impeachment.
Supreme Court edit
The 7-0 decision upholding the right of Senator John Quincy Adams to issue a public call for impeachment was handed down on April 21st, 1808. The case and decision was the first case to be heard in the Supreme Court concerning the First Amendment, and would be the only case until 1919. There was some speculation that the vote might be close, as the court consisted of 3 Jefferson appointees, however this was not to be the case. The more federalist leaning Washington appointees agreed on a decision affirming the First Amendment primarily because of their ideological agreement with Senator Adams. The more anti-federalist leaning Jefferson appointees agreed on a decision affirming the First Amendment primarily because of their natural distrust of an expansive federal government.
Majority Opinion edit
In a majority opinon written by Chief Justice John Marshall, the Supreme Court of the United States ruled that a public endorsement of impeachment constituted protected speech under the First Amendment of the United States Constitution, and was not a private intergovernmental pending investigation protected by executive priviege that the Jefferson Administration had argued.
The decision handed down by the court was more expansive than many had previously anticipated. Many in the Capitol believed that the most likely decision that the Supreme Court was going to hand down was a decision permitting other elected or appointed members of the federal government to publically endorse impeachment proceedings of members of government of each branch of government, not exclusively within their own branch, while affirming the impeachment process as an inherently bureaucratic intra-governmental process, forbidding private citizens or members of state governments to advocate for impeachment proceedings. The Marshall opinon however, decided that impeachment was instead a political process and that an endorsement of impeachment is an expression of political speech against grievances committed by the government and protected by the First Amendment. Marshall's language was sweeping:
The protection of political speech is a fundemental right under a republican and representative form of government. The founders are clear that the right of a man to cast his ballot is meant to be the least significant of our guarenteed rights in securing this republican form of government. This right is protected only by the perfection of the rights that come before it, namely the right to political speech and the right to petition the government for a redress of grievances. The first amendment is explicit and ubiquitous in it's language regarding this right. The insinuation that an elected government seperates itself from the political will of the people upon obtaining power, the process by which of securing this power being inherently political, would be a threatening precedent to set. The political election of a government is unable to be seperated from the political will and the consent to be governed by the people. Any action that an elected government takes is representative of that political will and is inherently a political action.
Reaction edit
Democratic-Republicans edit
Many prominent Democratic-Republicans and Federalists endorsed the decision handed down by the Marshall Court. The decision by Jefferson to petition against John Quincy Adams and attempt to shut down his public calls for impeachment were unpopular with Democratic-Republicans across the country. Many Southern voters beleived that Jefferson was betraying his commitment to a small and weak federal government. Democratic-Republicans were already upset with Jefferson for what they viewed as promoting an expansive federal government with the Louisianna Purchase and his usage of the Navy during the First Barbary War. Jefferson's political capital would continue to decline with this case and his administration would not get much done in the remaining months of his presidency.
Federalists edit
The Federalists, who traditionally supported more expansive acts of the federal government against individual rights, such as the Sedition Acts of 1798 passed by President John Adams, also publically endorsed the decision handed down by the Marshall Court.