United States v. Klein

Supreme Court of the United States · 1872 · Federal Courts

80 U.S. 128 (1872)

Updated August 1, 2026

Federal Courtscongressional control of judgmentsseparation of powersappellate jurisdictionexceptions clauserule of decisionpresidential pardonCourt of Claims

Facts

Treasury agents took possession of cotton belonging to V.F. Wilson as captured or abandoned property, sold it, and paid the proceeds into the Treasury. Wilson had taken and kept the amnesty oath under the President's proclamation, and the Court of Claims held that this entitled his administrator to recover the net proceeds. After this Court decided Padelford, Congress enacted a proviso in the appropriation act of July 12, 1870 declaring that pardons and acts done pursuant to pardon could not be used to support such claims and that, in cases founded on such proof, the courts' jurisdiction should cease and the suits be dismissed. The United States relied on that proviso to seek dismissal of this appeal.

Issue

Can Congress, by an appropriations proviso, require the Court of Claims and the Supreme Court to treat acceptance of a presidential pardon as conclusive evidence of disloyalty, deny the pardon its ordinary legal effect, and dismiss pending captured-property cases for want of jurisdiction? Also, does a presidential pardon with restoration of property entitle the pardoned owner to the proceeds of captured and abandoned property in the Treasury?

Rule

Congress's power to make exceptions and regulations to the Supreme Court's appellate jurisdiction does not include the power to prescribe a rule of decision in pending cases or to require courts to deny legal effect to presidential pardons. A presidential pardon, including amnesty, blots out the offense pardoned, removes its penal consequences, and, where restoration of property is expressly promised on satisfied conditions, gives the pardoned claimant an absolute right to those property proceeds covered by the promise.

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Lena Ortiz won a money judgment in the Court of Public Claims in Washington, D.C., after proving that a presidential amnesty restored her right to proceeds from noncombatant property earlier sold by federal officers and deposited in the Treasury. While the government's appeal was pending, Congress enacted a statute stating that in any pending appeal where a claimant relies on executive clemency, the Supreme Court must dismiss for want of jurisdiction once it determines that the judgment depends on that clemency.

Is the new statute constitutional as applied to Lena's pending appeal?

Explanation. The majority recognized that Congress may make exceptions to the Supreme Court's appellate jurisdiction. But it held unconstitutional a statute that withdrew jurisdiction only after the court found facts showing the claimant would prevail under settled law. That is not a simple jurisdictional exception; it is a prescribed rule of decision in a pending case. So the statute is invalid as applied to Lena's appeal.