The Constitution states that Justices "shall hold their Offices during good Behaviour." This means that the Justices hold office as long as they choose and can only be removed from office by impeachment. The only Justice to be impeached was Associate Justice Samuel Chase in 1805.
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The House of Representatives impeached Chase on eight articles of impeachment, all centering on Chases'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.
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Samuel Chase
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This article is about the Supreme Court justice. For the U.S. Congressman, see Samuel Chase (congressman). For the American tennis player, see Samuel T. Chase.
Samuel Chase
Samuel Chase.jpg
Associate Justice of the Supreme Court of the United States
In office
January 27, 1796 – June 19, 1811
Nominated by George Washington
Preceded by John Blair
Succeeded by Gabriel Duvall
Personal details
Born April 17, 1741
Somerset County, Maryland, British America
Died June 19, 1811 (aged 70)
Baltimore, Maryland, U.S.
Political party Federalist
Spouse(s) Ann Baldwin
Hannah Kilty
Signature
Nickname(s) Old Bacon Face, the Demosthenes of Maryland [1]
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 on grounds of letting his partisan leanings affect his court decisions but was acquitted by the Senate and remained in office.
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. The House of Representatives impeached Chase on eight articles of impeachment, all centering on Chases'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.
Contents
1 Youth and early career
2 Family and personal life
3 Career in Annapolis
3.1 Continental Congress
4 Judicial career
4.1 Impeachment
5 Death
6 References
7 Further reading
8 External links
Youth and early career
Samuel Chase was the only child of the Reverend Thomas Chase (c. 1703–1779) and his wife, Matilda Walker (? – by 1744), born near Princess Anne, Maryland.[2]
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.[2] He was admitted to the bar in 1761[3] 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."[4]
Family and personal life
In May 1762, Chase married Ann Baldwin, daughter of Thomas and Agnes Baldwin. Samuel and Ann had three sons and four daughters, with only four surviving to adulthood.[2] Ann 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.[2][5]
Career in Annapolis
In 1762, Chase was expelled from the Forensic Club, an Annapolis debating society, for "extremely irregular and indecent" behavior.[2]
In 1764, Chase was elected to the Maryland General Assembly where he served for 20 years.[3]
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." [6]
In 1769, he started construction of the mansion that would become known as the Chase–Lloyd House, which he sold unfinished in 1771. The house is now a National Historic Landmark.
He co-founded Anne Arundel County's Sons of Liberty chapter with his close friend William Paca, as well as leading opposition to the 1765 Stamp Act.[2]
Continental Congress
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.[3]
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.
Judicial career
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.[3]
On January 26, 1796, President George Washington appointed Chase as an associate justice of the Supreme Court of the United States. Chase served on the court until his death on June 19, 1811.[3]
Impeachment
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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."[7] 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.[8] 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 that he wished them to indict for seditious behavior.[9] 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?"[10]
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. [11] 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.[12] He is the only U.S. Supreme Court justice to have been impeached.[3] Judge Alexander Pope Humphrey recorded in the Virginia Law Register an account of the impeachment trial and acquittal of Chase.[13]
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.[14]
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.[15]
Death
Samuel Chase died of a heart attack in 1811. He was interred in what is now Baltimore's Old Saint Paul's Cemetery.[16][17]
Samuel Chase Impeached
March 12, 1804
Supreme Court justice Samuel Chase, an ardent Federalist supporter, was known for his open partisanship both on and off the bench. He campaigned vigorously for John Adams in the election of 1800, and in 1803, gave a grand jury charge in the U.S. circuit court in Maryland that was sharply critical of the Republicans for repealing the 1801 judiciary statute and abolishing the circuit judgeships that act had established. The grand jury charge proved highly controversial and led many to call for Chase’s removal from the bench. In March 1804, after debating what constituted proper grounds for impeachment, the House of Representatives voted to impeach Chase. The Maryland grand jury charge formed the basis for one of the eight articles of impeachment because of its allegedly seditious intent, while most of the others focused on allegedly improper behavior during politically charged trials such as the Sedition Act prosecutions. During his twenty-two day trial before the Senate, Chase argued that he could not be impeached for errors in judgment or improper behavior on the bench, but rather only for an indictable offense. On March 1, 1805, the Senate acquitted Chase when none of the eight articles of impeachment secured the votes of two-thirds of the members as was required for conviction. Chase’s impeachment helped to set the parameters of what kinds of conduct would warrant a judge’s removal from the bench. Although there had been one earlier judicial impeachment, involving John Pickering of New Hampshire, it was such a clear case of disability that it was not very useful as a precedent. Chase’s acquittal served as a tacit victory for his position that an indictable offense was required to meet the “high crimes and misdemeanors” standard for the impeachment and conviction of a federal judge. More than two centuries later, only eight federal judges have been removed by impeachment. In the twentieth century, Congress examined proposals for the removal of federal judges whose conduct did not rise to the level required for impeachment, but none was enacted, due in large part to doubts about the constitutionality of such a measure.
Timeline:
The Administration of the Federal Courts
Democrat Leaders Warn SCOTUS
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