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Hayburn’s Case

United States Supreme Court
2 U.S. 408 (1792)


Facts

The Invalid Pensions Act of 1792 (the Act) provided financial assistance for injured veterans of the Revolutionary War [Quimbee editor’s note: “invalid” as used here is a noun meaning a disabled person]. The Act held the federal circuit courts responsible for determining the eligibility of applicants for benefits by hearing evidence on their military service, war injuries, and disabilities, and then making a calculation of benefits. The court would then forward the information of qualified applicants to the secretary of war, along with the recommended amount of benefits. The Act directed the secretary to then place the qualified applicants’ name on the pension list, unless the secretary suspected the award was made by mistake or otherwise granted improperly, in which case the name was reported to congress for review. Attorney General Randolph filed a petition for mandamus in the United States Supreme Court to command the Circuit Court for the District of Pennsylvania to fulfill its duties under the Act. The petition was filed ex officio, not on behalf of any specific petition for benefits under the Act. The Supreme Court questioned Randolph’s right to file the petition and asked for further support for his position. The Court then disallowed the petition, because it was not filed on behalf of any applicant. Randolph then amended the petition as being on behalf of William Hayburn. The Court agreed to hold the petition under advisement until its next term, but no decision was ever rendered, since congress in the interim provided other means of relief for the veterans. Nevertheless, several circuit courts wrote opinions or letters on the issue of whether the directives of the Act to the courts were proper.

Rule of Law

The rule of law is the black letter law upon which the court rested its decision.

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Issue

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Holding and Reasoning (Advisory opinions of circuit courts)

The holding and reasoning section includes:

  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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