Newberry v. United States facts for kids
Quick facts for kids Newberry v. United States |
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| Argued January 7, 10, 1921 Decided May 2, 1921 |
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| Full case name | Newberry, et al. v. United States |
| Citations | 256 U.S. 232 (more)
41 S. Ct. 469; 65 L. Ed. 913; 1921 U.S. LEXIS 1632
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| Prior history | Error to the District Count of the U.S. for the Western District of Michigan |
| Holding | |
| Authority to control party primaries or conventions for designating candidates not bestowed on Congress by U.S. Constitution. | |
| Court membership | |
| Case opinions | |
| Majority | McReynolds, joined by Holmes, Day, Van Devanter; McKenna (in part) |
| Concurrence | McKenna (in part) |
| Concur/dissent | White |
| Concur/dissent | Pitney, joined by Brandeis, Clarke |
| Laws applied | |
| Federal Corrupt Practices Act; 1913 Mich. Pub. Acts 109, Sec. 1; U.S. Const. Art. I, Sec. 4; U.S. Const., 17th Amend. | |
Newberry v. United States was an important decision by the Supreme Court of the United States. In 1921, the Court decided that the U.S. Constitution did not give the United States Congress the power to control how political parties choose their candidates in primary elections. This ruling meant that parts of a law called the Federal Corrupt Practices Act were no longer valid. That law had tried to limit how much money candidates and political groups could spend in primary elections for federal offices.
Contents
Why This Case Happened
Rules for Campaign Money
During a time called the Progressive Era, many people wanted to make rules about how political campaigns were funded. This led to new laws. In 1907, the Tillman Act was passed. It stopped companies from directly giving money to political campaigns.
Then came the Federal Corrupt Practices Act (FCPA) in 1910. This law was updated in 1911. It set two main limits on spending in federal elections:
- Candidates could not spend more than what their state law allowed to get nominated and elected.
- Candidates for the United States House of Representatives could not spend more than $5,000.
- Candidates for the United States Senate could not spend more than $10,000.
Michigan also had its own law. It said that candidates for federal office could not spend more than 25% of their future federal salary to get nominated. They could spend another 25% for the general election. At that time, this was about $3,750 for each part of the election.
Truman Newberry's Election
Truman Handy Newberry was a businessman from Michigan. He had also been the Secretary of the Navy. In 1918, he decided to run for the U.S. Senate as a Republican. His main opponent in the primary election was Henry Ford, who was famous for making cars.
The primary election was very competitive. Newberry was said to have spent a lot of money, possibly over $100,000, to win his party's nomination. Newberry won against Ford and then won the general election. Henry Ford challenged the results. He used his connections in the government to get Congress and the United States Department of Justice to investigate Newberry.
Newberry was later found guilty of violating the FCPA. He then appealed his case to the U.S. Supreme Court. He argued that the FCPA was against the Constitution.
The Supreme Court's Decision
What the Majority Said
Justice James Clark McReynolds wrote the main opinion for the Supreme Court. The Court decided that the U.S. Constitution did not give Congress the power to control primary elections or how political parties choose their candidates.
Justice McReynolds explained that Congress gets its power over federal elections only from Article I, Section 4, of the Constitution. He said that the Seventeenth Amendment, which was added in 1913, did not change the meaning of "election." So, it did not give Congress new powers over primaries. McReynolds argued that primary elections are not the same as general elections for office.
He believed that neither the words of the Constitution nor what its original writers intended allowed Congress to regulate primaries. He also said that Congress did not need to regulate primaries to do its job under Article I, Section 4. If Congress were allowed to do so, it would take away rights that belong to the states and the people.
Other Opinions
Justice Joseph McKenna agreed with part of the decision. He agreed that the FCPA was unconstitutional before the Seventeenth Amendment was adopted. However, he was not sure if it was constitutional after the amendment.
Justice Mahlon Pitney also agreed with part of the decision. Justices Louis D. Brandeis and John Hessin Clarke joined him. Justice Pitney thought that Congress could regulate primary elections. But he believed the lower court made a mistake in its instructions to the jury. He would have sent the case back for a new trial.
Chief Justice White disagreed with the main decision. He believed there was nothing wrong with Congress regulating primaries. He also thought that when Congress passed the Seventeenth Amendment, it intended to allow regulation of primaries. Like Justice Pitney, he found a mistake in the jury instructions and would have sent the case back for a new trial.
After the Supreme Court's ruling, the U.S. Senate investigated Newberry again. The Senate found that Newberry had not broken the FCPA. They allowed him to keep his seat but said they did not approve of how much money he spent in his primary campaign. Facing new efforts to remove him, Newberry resigned from the Senate on November 18, 1922.
See also
- List of United States Supreme Court cases, volume 256
- United States v. Classic
