West v. Barnes
| West v. Barnes | |
|---|---|
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| Argued August 2, 1791 Decided August 3, 1791 |
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| Full case name | West v. Barnes |
| Citations | 2 U.S. 401 (more) |
| Holding | |
| The Court held that "Writs of error to remove causes to this court from inferior courts, can regularly issue only from the clerk's office of the court. Motion refused." | |
| Court membership | |
| Case opinions | |
| Majority | Unanimous |
West v. Barnes, 2 U.S. 401 (1791), was the first United States Supreme Court decision and the earliest case calling for oral argument.Van Staphorst v. Maryland (1791) was docketed prior to West v. Barnes but settled before the Court heard the case: West was argued on August 2, 1791 and decided on August 3, 1791. Collet v. Collet (1791) was the first appellate case docketed with the Court but was dropped before it could be heard. Supreme Court Reporter Alexander Dallas did not publish the justices' full opinions in West v. Barnes, which were published in various newspapers around the country at the time, but he published an abbreviated summary of the decisions.
The Court ultimately decided the case on procedural grounds, holding that a writ of error (an appeal) must be issued within ten days by the Clerk of the Supreme Court of the United States as required by federal statute, and not by a lower court located closer to the plaintiff in Rhode Island. As a result of this case, Congress ultimately changed this procedure with the ninth section of the Judicial Act of 1792 allowing circuit courts to issue these writs, thereby assisting citizens living far away from the capital.
This was one of the earliest potential cases of judicial review in the United States where the Court had the opportunity to overturn a Rhode Island state statute regarding lodging payment of a debt in paper currency in fulfillment of a contract. The court did not exercise judicial review in deference to the legislature. The court ultimately decided against William West, the petitioner, on procedural grounds.
William West was a farmer, revolutionary war militia general, anti-federalist leader, and judge from Scituate, Rhode Island. West owed a mortgage on his farm from a failed molasses deal in 1763 to the Jenckes family from Providence. West made payments on the mortgage for twenty years, and in 1785 asked the state for permission to conduct a lottery to help pay off the remainder. Due to his service during the Revolution, the state granted him permission. Much of the proceeds were paid in paper currency instead of gold or silver. West tendered payment in the paper currency as allowed by state statute by "lodging" the funds with a state judge to be collected within ten days.
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