Sheldon v. Sill

From Judgepedia

Sheldon v. Sill
Supreme Court of the United States
Full case name	Thomas Sheldon and Eleanor Sheldon His Wife v. William E Sill
Date decided	Feb 21, 1850
Citations	49 U.S. 441 (1850)
Judges sitting	Chief Justice Roger Brooke Taney, Associate Justices John McLean, James Moore Wayne, John Catron, John McKinley, Peter Vivian Daniel, Samuel Nelson, Levi Woodbury, Robert Cooper Grier

Sheldon v. Sill is an important decision by the Supreme Court of the United States which limited the amount of discretion Congress has in enacting legislation to limit the types of Cases that may be heard by the lower federal courts. The Supreme Court held that while it may limit the type of cases which may be heard by the Supreme Court under Article III of the U.S. Constitution, it may not do so to lower courts created by statute.

Legal Reasoning

Under Article III, there are two types of federal courts. The Supreme Court, which is created by the Constitution, and lower courts which the constitution stipulates may be created by statute. ^[1] Congress did so by the Judiciary Act. However: The eleventh section of the Judiciary Act, which defines the jurisdiction of the Circuit Courts, restrains them from taking 'cognizance of any suit to recover the contents of any promissory note or other chose in action, in favor of an assignee, unless a suit might have been prosecuted in such court to recover the contents, if no assignment had been made, except in cases of foreign bills of exchange' . . . It must be admitted, that if the Constitution had ordained and established the inferior courts, and distributed to them their respective powers, they could not be restricted or divested by Congress. But . . . it has made no such distribution . . . (Consequentially), Congress, having the power to establish the courts, must define their (the inferior courts') respective jurisdictions. ^[2]

In Sheldon, then, the Supreme Court ruled that:

Congress may withhold from any court of its creation jurisdiction of any of the enumerated controversies. Courts created by statute can have no jurisdiction but such as the statute confers. No one of them can assert a just claim to jurisdiction exclusively conferred on another, or withheld from all . . . The Constitution has defined the limits of the judicial power of the United States, but has not prescribed how much of it shall be exercised by the Circuit Court; consequently, the statute which does prescribe the limits of their jurisdiction, cannot be in conflict with the Constitution, unless it confers powers not enumerated therein. ^[3]

References