United States v. Kirby
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- This case is about statutory construction. For the 1931 case on taxation of cancelled debt, see United States v. Kirby Lumber Co.
| United States v. Kirby | ||||||||||||
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| Decided April 15, 1869 |
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| Chief Justice: Salmon P. Chase Associate Justices: Samuel Nelson, Robert Cooper Grier, Nathan Clifford, Noah Haynes Swayne, Samuel Freeman Miller, David Davis, Stephen Johnson Field |
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| Majority by: Field Joined by: Chase, Nelson, Grier, Clifford, Swayne, Davis Miller took no part in the consideration or decision of the case. |
United States v. Kirby, 74 U.S. 482 (1868), was a case in which the Supreme Court of the United States held that statutes must be construed reasonably.
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[edit] Facts
In 1867 Farris, who was a carrier of the mail, was indicted for murder in the Circuit Court of Gallatin County, Kentucky. The state court judge issued a bench warrant and directed Kirby, the sheriff of Gallatin County, to seize Farris and to bring him before the state court. Kirby did so and by that action effectively prevented Farris from delivering the mail. The federal government gave a literal reading to the Act of March 3, 1825 and obtained an indictment from a federal grand jury charging Sheriff Kirby with obstruction of the mail. The question of "whether the arrest of the mail-carrier upon the bench warrant from the Circuit Court of Gallatin County was, in the circumstances, an obstruction of the mail within the meaning of the Act of Congress," was certified to the US Supreme Court.
[edit] Issue
May a sheriff be prosecuted for arresting a postal worker on a warrant when the statute made it a crime to "knowingly and willfully obstruct or retard the passage of the mail...?"
[edit] Holding
Mr. Justice Field, for a unanimous court, answered the certified question in the negative by applying the cardinal rule "that all laws should receive a sensible construction," and that literal interpretations which "lead to injustice, oppression, or an absurd consequence" should be avoided. The Court concluded that "The reason of the law in such cases should prevail over its letter."
[edit] Result
The case establishes the rule that criminal statutes must be given a sensible rather than a literal interpretation was deeply rooted in the common law. The Act of March 3, 1825 was involved in Kirby. That Act prohibited any person from knowingly and willfully obstructing or retarding the passage of the mail. But the arrest of a mail carrier for murder is not obstruction of the mails.
[edit] See also
[edit] External links
- ^ 74 U.S. 482 Full text of the opinion courtesy of Findlaw.com.
