Samuel Chase (April 17, 1741 – June 19, 1811) was an Associate Justice of the United States Supreme Court and a signatory to the United States Declaration of Independence as a representative of Maryland. He was impeached by the House of Representatives on grounds of letting his partisan leanings affect his court decisions but was acquitted by the Senate and remained in office.
|Associate Justice of the Supreme Court of the United States|
January 27, 1796 – June 19, 1811
|Nominated by||George Washington|
|Preceded by||John Blair|
|Succeeded by||Gabriel Duvall|
|Born||April 17, 1741|
Somerset County, Maryland, British America
|Died||June 19, 1811 (aged 70)|
Baltimore, Maryland, U.S.
|Nickname(s)||Old Bacon Face, the Demosthenes of Maryland |
Born near Princess Anne, Maryland, Chase established a legal practice in Annapolis, Maryland. He served in the Maryland General Assembly for several years and favored independence during the American Revolution. He won election to the Continental Congress before serving on the Baltimore District Criminal Court and the Maryland General Court. In 1796, President George Washington appointed Chase to the United States Supreme Court.
After the 1800 elections, President Thomas Jefferson and the Democratic-Republicans sought to weaken Federalist influence on the federal courts. Chase's actions on the court had been accused of demonstrating bias, and Jefferson believed that Chase should be removed from office, a process that required a vote in both the Senate and the House of Representatives. The House impeached Chase on eight articles of impeachment, all centering on Chase's alleged political bias. The Senate voted to acquit Chase on all counts, and Chase served on the Supreme Court until his death in 1811. Some historians have argued that Chase's acquittal set an important precedent regarding the independence of the federal judiciary.
Youth and early careerEdit
His father was a clergyman who immigrated to Somerset County to become a priest in a new church. Samuel was educated at home. He was eighteen when he left for Annapolis where he studied law under attorney John Hall. He was admitted to the bar in 1761 and started a law practice in Annapolis. It was during his time as a member of the bar that his colleagues gave him the nickname of "Old Bacon Face."
Family and personal lifeEdit
In May 1762, Chase married Anne Baldwin, daughter of Thomas and Agnes Baldwin. Samuel and Anne had three sons and four daughters, with only four surviving to adulthood. Anne died in 1776.
In 1784, Chase traveled to England to deal with Maryland's Bank of England stock, where he met Hannah Kilty, daughter of Samuel Giles, a Berkshire physician. They were married later that year and had two daughters, Hannah and Elisa.
Career in AnnapolisEdit
In 1762, Chase was expelled from the Forensic Club, an Annapolis debating society, for "extremely irregular and indecent" behavior.
In 1766, he became embroiled in a war of words with a number of loyalist members of the Maryland political establishment. In an open letter dated July 18, 1766, Chase attacked Walter Dulany, George Steuart (1700–1784), John Brice (1705–1766), and others for publishing an article in the Maryland Gazette Extraordinary of June 19, 1766, in which Chase was accused of being: "a busy, reckless incendiary, a ringleader of mobs, a foul-mouthed and inflaming son of discord and faction, a common disturber of the public tranquility". In his response, Chase accused Steuart and the others of "vanity...pride and arrogance", and of being brought to power by "proprietary influence, court favour, and the wealth and influence of the tools and favourites who infest this city."
From 1774 to 1776, Chase was a member of the Annapolis Convention. He represented Maryland at the Continental Congress, was re-elected in 1776 and signed the United States Declaration of Independence.
He remained in the Continental Congress until 1778. The involvement of Chase in an attempt to corner the flour market, using insider information gained through his position in the Congress, resulted in his not being returned to the Continental Congress and damaging his reputation.
In 1786, Chase moved to Baltimore, which remained his home for the rest of his life. In 1788, he was appointed chief justice of the District Criminal Court in Baltimore and served until 1796. In 1791, he became Chief Justice of the Maryland General Court, again serving until 1796.
President Thomas Jefferson, alarmed at the seizure of power by the judiciary through the claim of exclusive judicial review, led his party's efforts to remove the Federalists from the bench. His allies in Congress had, shortly after his inauguration, repealed the Judiciary Act of 1801, abolishing the lower courts created by the legislation and terminating their Federalist judges despite lifetime appointments; Chase, two years after the repeal in May 1803, had denounced it in his charge to a Baltimore grand jury, saying that it would "take away all security for property and personal liberty, and our Republican constitution will sink into a mobocracy." Earlier in April 1800, Chase acting as a district judge, had made strong attacks upon Thomas Cooper, who had been indicted under the Alien and Sedition Acts; Chase had taken the air of a prosecutor rather than a judge. Also in 1800, when a grand jury in New Castle, Delaware declined to indict a local printer, Chase refused to discharge them, saying he was aware of one specific printer whom he wished them to indict for seditious behavior. Jefferson saw the attack as indubitable bad behavior and an opportunity to reduce the Federalist influence on the judiciary by impeaching Chase, launching the process from the White House when he wrote to Congressman Joseph Hopper Nicholson of Maryland, asking: "Ought the seditious and official attack [by Chase] on the principles of our Constitution . . .to go unpunished?"
Virginia Congressman John Randolph of Roanoke took up the challenge and took charge of the impeachment. The House of Representatives served Chase with eight articles of impeachment in late 1803, one of which involved Chase's handling of the trial of John Fries. Two more focused on his conduct in the political libel trial of James Callender. One article covered Chase's conduct with the New Castle grand jury, charging that he "did descend from the dignity of a judge and stoop to the level of an informer by refusing to discharge the grand jury, although entreated by several of the said jury so to do." Three articles focused on procedural errors made during Chase's adjudication of various matters, and an eighth was directed at his "intemperate and inflammatory … peculiarly indecent and unbecoming … highly unwarrantable … highly indecent" remarks while "charging" or authorizing a Baltimore grand jury. On March 12, 1804, the House voted 73 to 32 to impeach Chase. The United States Senate—controlled by the Jeffersonian Democratic-Republicans—began the impeachment trial of Chase on February 9, 1805, with Vice President Aaron Burr presiding and Randolph leading the prosecution.
All the counts involved Chase's work as a trial judge in lower circuit courts. (In that era, Supreme Court justices had the added duty of serving as individuals on circuit courts, a practice that was ended in the late 19th century.) The heart of the allegations was that political bias had led Chase to treat defendants and their counsel in a blatantly unfair manner. Chase's defense lawyers called the prosecution a political effort by his Republican enemies. In answer to the articles of impeachment, Chase argued that all of his actions had been motivated by adherence to precedent, judicial duty to restrain advocates from improper statements of law, and considerations of judicial efficiency.
The Senate voted to acquit Chase of all charges on March 1, 1805. There were 34 senators present (25 Republicans and 9 Federalists), and 23 votes were needed to reach the required two-thirds majority for conviction/removal from office. Of the eight votes cast, the closest vote was 18 for conviction/removal from office and 16 for acquittal in regards to the Baltimore grand jury charge. He is the only U.S. Supreme Court justice to have been impeached. Judge Alexander Pope Humphrey recorded in the Virginia Law Register an account of the impeachment trial and acquittal of Chase.
The impeachment raised constitutional questions over the nature of the judiciary and was the end of a series of efforts to define the appropriate extent of judicial independence under the Constitution. It set the limits of the impeachment power, fixed the concept that the judiciary was prohibited from engaging in partisan politics, defined the role of the judge in a criminal jury trial, and clarified judicial independence. The construction was largely attitudinal, as it modified political norms without codifying new legal doctrines.
The acquittal of Chase—by lopsided margins on several counts—set an unofficial precedent that many historians say helped ensure the independence of the judiciary. As Chief Justice William Rehnquist noted in his book Grand Inquests, some senators declined to convict Chase despite their partisan hostility to him, apparently because they doubted that the mere quality of his judging was grounds for removal. All impeachments of federal judges since Chase have been based on allegations of legal or ethical misconduct, not on judicial performance. For their part, federal judges since that time have generally been much more cautious than Chase in trying to avoid the appearance of political partisanship.
Legacy and honorsEdit
- Scharf, John Thomas (1879). History of Maryland: 1765–1812. p. 179.
- "Chase, Samuel (1741–1811)". Maryland Online Encyclopedia (MdOE). Maryland Online Encyclopedia, a joint project of the Maryland Historical Society, the Maryland Humanities Council, the Enoch Pratt Free Library, and the Maryland State Department of Education. 2005. Archived from the original on May 9, 2008. Retrieved December 5, 2007.
- "Samuel Chase". The Supreme Court Historical Society. Archived from the original on July 13, 2007. Retrieved December 5, 2007.
- "Marbury v. Madison: Nail-Biting Drama?". Legalities, ABC News Blog. Retrieved August 27, 2009.
- "Biography of Anne Baldwin Chase – Colonial Hall".
- Sanderson, John J, p. 67, Biography of the Signers To the Declaration of Independence, Volume 5, published by R W Pomery (1823). Retrieved January 21, 2010.
- Rehnquist, William H. Grand Inquests: The Historic Impeachments of Justice Samuel Chase and President Andrew Johnson. Quill: 1992, p. 52.
- The Kentucky and Virginia Resolutions; Guideposts of Limited Government by WILLIAM J. WATKINS, JR.
- "The Sedition Act Trials – Historical Background and Documents". Federal Judicial Center. Retrieved February 4, 2015.
- Jerry W. Knudson, "The Jeffersonian Assault on the Federalist Judiciary, 1802–1805: Political Forces and Press Reaction," American Journal of Legal History 1970 14(1): 55–75; Richard Ellis, "The Impeachment of Samuel Chase," in American Political Trials, ed. by Michael R. Belknap (1994) pp. 57–76, quote on p. 64.
- Samuel Chase – The Samuel Chase Impeachment Trial
- Jost, Kenneth (March 14, 2012). Supreme Court A to Z. SAGE. ISBN 9781608717446.
- Humphrey, Alexander Pope (1899). "The Impeachment of Samuel Chase". The Virginia Law Register. 5 (5): 281–302. doi:10.2307/1098896. JSTOR 1098896.
- Keith E. Whittington, "Reconstructing the Federal Judiciary: The Chase Impeachment and the Constitution," Studies in American Political Development 1995 v9#1: 55–116.
- Richard Lillich, "The Chase Impeachment," American Journal of Legal History 1960 4(1): 49–72.
- "Christensen, George A. (1983) Here Lies the Supreme Court: Gravesites of the Justices, Yearbook". Archived from the original on September 3, 2005. Retrieved September 3, 2005. Supreme Court Historical Society at Internet Archive.
- See also, Christensen, George A., Here Lies the Supreme Court: Revisited, Journal of Supreme Court History, Volume 33 Issue 1, pp. 17–41 (February 19, 2008), University of Alabama.
- Abraham, Henry J. (1992). Justices and Presidents: A Political History of Appointments to the Supreme Court (3rd ed.). New York: Oxford University Press. ISBN 0-19-506557-3.
- Cushman, Clare (2001). The Supreme Court Justices: Illustrated Biographies, 1789–1995 (2nd ed.). (Supreme Court Historical Society, Congressional Quarterly Books). ISBN 1-56802-126-7.
- Frank, John P. (1995). Friedman, Leon; Israel, Fred L. (eds.). The Justices of the United States Supreme Court: Their Lives and Major Opinions. Chelsea House Publishers. ISBN 0-7910-1377-4.
- Hall, Kermit L., ed. (1992). The Oxford Companion to the Supreme Court of the United States. New York: Oxford University Press. ISBN 0-19-505835-6.
- Haw, James; F. F. Beirne; R. S. Jett (1980). Stormy Patriot: the Life of Samuel Chase. Baltimore: Maryland Historical Society. ISBN 0-938420-00-3.
- Martin, Fenton S.; Goehlert, Robert U. (1990). The U.S. Supreme Court: A Bibliography. Washington, D.C.: Congressional Quarterly Books. ISBN 0-87187-554-3.
- Papenfuse, Edward C (July 1, 1987). Biographical Dictionary of the Maryland Legislature. 2 Vol. Set. Baltimore: The Johns Hopkins University Press. ISBN 0-8018-3570-4.
- Urofsky, Melvin I. (1994). The Supreme Court Justices: A Biographical Dictionary. New York: Garland Publishing. p. 590. ISBN 0-8153-1176-1.
|Wikisource has the text of a 1999 New International Encyclopedia article about "Samuel Chase".|
- Samuel Chase at the Biographical Directory of Federal Judges, a public domain publication of the Federal Judicial Center.
- ColonialHall.com: Samuel Chase
- Samuel Chase, Freedom Firebrand – Delmarva Heritage Series
- Oyez Project, Supreme Court media, Samuel Chase.
- Samuel Chase, Supreme Court Historical Society.
- Booknotes interview with William Rehnquist on Grand Inquests: The Historic Impeachments of Justice Samuel Chase and President Andrew Johnson, July 5, 1992.
| Associate Justice of the Supreme Court of the United States