Murray’s Lessee v. Hoboken Land and Improvement Co
Murray’s Lessee v. Hoboken Land and Improvement Co. is a significant Supreme Court case that addresses the intersection of government authority, property rights, and due process under the Constitution. The case originated when Samuel Swartwout, a customs collector, faced a shortfall of over a million dollars in his accounts. To recover these funds, the U.S. Treasury Department invoked a congressional statute from 1820 to place a lien on Swartwout’s property without prior judicial authorization. Swartwout challenged this action, arguing that it violated the Fifth Amendment's due process protections.
In a unanimous decision, the Supreme Court upheld the government's actions, determining that judicial proceedings were not necessary for the government to reclaim its funds based on historical legal practices. Justice Benjamin R. Curtis emphasized that while Congress could determine what constitutes "due process," it could not do so arbitrarily. This ruling significantly shaped the interpretation of due process in American law, influencing legal practices related to government seizures and property rights in the subsequent decades. The case highlights ongoing tensions between individual rights and governmental powers, providing a crucial reference point in discussions of constitutional law.
Murray’s Lessee v. Hoboken Land and Improvement Co.
Date: February 19, 1856
Citation: 18 How. (59 U.S.) 272
Issue: Interpretation of due process
Significance: In its first sustained definition of “due process of law,” the Supreme Court ruled that the Treasury Department did not violate the Fifth Amendment when it used administrative warrants to recovery embezzled funds.
The accounts of a customs collector, Samuel Swartwout, were short more than a million dollars. The Treasury Department used a congressional law of 1820 to place a lien on his property without prior judicial approval. Swartwout claimed that seizing his property without a judicial proceeding violated the due process requirements of the Fifth Amendment.
Speaking for a unanimous Supreme Court, Justice Benjamin R. Curtis upheld the constitutionality of both the action and the 1820 law. To determine the meaning of “due process,” the Court must examine the Constitution itself, then look to the “settled usages and modes of proceedings existing in the common and statute law of England,” as modified under U.S. conditions. According to this tradition, judicial proceedings were not required in order for the government to recover its funds. However, Curtis put the government on notice that the due process clause “cannot be so construed as to leave Congress free to make any process ’due process of law’ by its mere will.” The interpretation of due process in Murray’s Lessee greatly influenced U.S. law, especially during the second half of the nineteenth century.