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Taylor v. Beckham

Taylor v. Beckham
Seal of the United States Supreme Court.svg
Argued April 30 – May 1, 1900
Decided May 21, 1900
Full case name William S. Taylor and John Marshall, Plaintiffs in Err., v. J. C. W. Beckham Defendant in Err.
Citations 178 U.S. 548 (more)
Prior history 21 Ky. L. Rep. 1735, 56 S. W. 177
Holding
Court refused to intervene in the case, claiming that no federal questions were at issue. The Kentucky Court of Appeals' decision in favor of Beckham was allowed to stand.
Court membership
Case opinions
Majority Fuller, joined by Gray, Shiras, White, Peckham
Concurrence McKenna
Concur/dissent Brewer, joined by Brown
Dissent Harlan

Taylor v. Beckham, 178 U.S. 548 (1900), was a case heard before the Supreme Court of the United States on April 30 and May 1, 1900, to decide the outcome of the disputed Kentucky gubernatorial election of 1899. The litigants were Republican gubernatorial candidate William S. Taylor and Democratic lieutenant gubernatorial candidate J. C. W. Beckham. In the November 7, 1899, election, Taylor received 193,714 votes to Democrat William Goebel's 191,331. This result was certified by a 2–1 decision of the state's Board of Elections. Goebel challenged the election results on the basis of alleged voting irregularities, and the Democrat-controlled Kentucky General Assembly formed a committee to investigate Goebel's claims. Goebel was shot on January 30, 1900, one day before the General Assembly approved the committee's report declaring enough Taylor votes invalid to swing the election to Goebel. As he lay dying of his wounds, Goebel was sworn into office on January 31, 1900. He died on February 3, 1900, and Beckham ascended to the governorship.

Claiming the General Assembly's decision was invalid, Taylor sued to prevent Beckham from exercising the authority of the governor's office. Beckham countersued Taylor for possession of the state capitol and governor's mansion. The suits were consolidated and heard in Jefferson County circuit court, which claimed it had no authority to interfere with the method of deciding contested elections prescribed by the state constitution, an outcome that favored Beckham. The Kentucky Court of Appeals upheld the circuit court's decision on appeal and rejected Taylor's claim that he had been deprived of property without due process by stating that an elective office was not property and thus not protected by the Fourteenth Amendment.


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