Hagood v. Southern
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| Hagood v. Southern | |
| Reference: 117 U.S. 52 | |
| Term: 1886 | |
| Important Dates | |
| Argued: January 12-13, 1886 Decided: March 1, 1886 | |
| Outcome | |
| United States Circuit Court for the District of South Carolina reversed | |
| Majority | |
| Stanley Matthews • Morrison Waite • Samuel Freeman Miller • Stephen Johnson Field • Joseph Bradley • John Harlan I • William Burnham Woods • Horace Gray • Samuel Blatchford | |
Hagood v. Southern is a case decided on March 1, 1886, by the United States Supreme Court holding that state officials are protected by the sovereign immunity of the Eleventh Amendment of the U.S. Constitution and cannot be sued by citizens. The case concerned a suit to levy a tax to fund revenue bond scrips for the Blue Ridge Railroad Company. The Supreme Court reversed the decision of the United States Circuit Court for the District of South Carolina.[1]
Why it matters: The Supreme Court's decision in this case reaffirmed that lawsuits against state officials were equivalent to lawsuits against states, which are barred by the Eleventh Amendment. To read more about the impact of Hagood v. Southern click here.
Background
The South Carolina general assembly enacted a law on September 15, 1868, to authorize aid for the Blue Ridge Railroad Company by issuing $4,000,000 in bonds. A separate law was enacted on March 2, 1872, to relieve the state of South Carolina of the responsibility of repaying said bonds. The act stated that, in exchange for withdrawing the balance of the $4,000,000 bonds, "the state treasurer should issue in lieu thereof, to the amount of $1,500,000, certificates of indebtedness, styled revenue bond scrip, expressing that the sum mentioned therein was due by the State of South Carolina to bearer, and that the same would be received in payment of taxes and all other dues to the state except special tax levied to pay interest on the public debt."[1]
Following this legislation, South Carolina abolished the office of state auditor and granted the authority of that office to the comptroller general. The state also repealed the legislation responsible for an annual tax to repay the bond scrip and prohibited the comptroller general from levying taxes without the authority of a statute. An act was also passed to prohibit state and county officers from accepting payments of taxes in revenue bond scrips.
The plaintiffs argued that the Blue Ridge Railroad Company was indebted to the state of South Carolina for property taxes from 1872 totaling $10,845.33. The railroad company had made revenue bond scrips to the treasurers of Oconee County and Anderson County, but the comptroller general refused payment. A bill was filed that aimed to require the county treasurers to receive the revenue bond scrip as payment of the taxes due by the railroad company to the state of South Carolina.[1][2]
Oral argument
Oral argument was held between January 12, 1886, and January 13, 1886. The case was decided on March 1, 1886.[1]
Decision
The Supreme Court decided unanimously to reverse the decision of the United States Circuit Court for the District of South Carolina. Justice Stanley Matthews delivered the opinion of the court. Justices Stephen Johnson Field and John Harlan I adhered to the views they had expressed in their dissenting opinions in Louisiana v. Jumel, but concurred that the facts of Hagood v. Southern required a reversal of the circuit court's decision.[1]
Opinions
Opinion of the court
Justice Stanley Matthews, writing for the court, argued that pursuant to the Eleventh Amendment, a citizen cannot sue a state without its consent. Matthews highlighted the decision in Louisiana v. Jumel which held that officers of the state cannot be sued for acting on behalf of the state. The court upheld the decision in Louisiana v. Jumel and ruled that the Blue Ridge Railroad Company could not file a suit to force state officials to levy a tax to fund the revenue bond scrip.[1]
| “ | If this case is not within the class of those forbidden by the constitutional guarantee to the states of immunity from suits in federal tribunals, it is difficult to conceive the frame of one which would be. If the state is named as a defendant, it can only be reached either by mesne or final process through its officers and agents, and a judgment against it could neither be obtained nor enforced except as the public conduct and government of the ideal political body called a state could be reached and affected through its official representatives. A judgment against these latter, in their official and representative capacity, commanding them to perform official functions on behalf of the state according to the dictates and decrees of the court, is, if anything can be, a judicial proceeding against the state itself. If not, it may well be asked what would constitute such a proceeding? In the present cases, the decrees were not only against the defendants in their official capacity, but, that there might be no mistake as to the nature and extent of the duty to be performed, also against their successors in office. [3] | ” |
| —Stanley Matthews, majority opinion in Hagood v. Southern[1] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Sovereign immunity
Hagood v. Southern reaffirmed the decision in Louisiana v. Jumel which established that state officials cannot be held responsible in federal court for acting on behalf of the state. State officials are protected by the state's sovereign immunity, which means that states are immune from civil suits, criminal prosecutions, and other legal actions unless they consent to the lawsuit. In this case, sovereign immunity was extended to protect the state's comptroller general from being forced to levy a tax to fund the revenue bond scrip.[1]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
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