Runkle v. United States facts for kids
Quick facts for kids Runkle v. United States |
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| Argued April 22, 1887 Decided May 27, 1887 |
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| Full case name | Runkle v. United States |
| Citations | 122 U.S. 543 (more)
7 S. Ct. 1141; 30 L. Ed. 1167; 1887 U.S. LEXIS 2136
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| Holding | |
| The president cannot delegate the power vested in him to pass finally upon a court-martial sentence because he is the only person bestowed with the judicial power of making a final determination. | |
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| Case opinions | |
| Majority | Waite, joined by unanimous |
Runkle v. United States, a Supreme Court case from 1887, decided something very important about the President's power. The Court ruled that the President is the only person who can give the final approval for decisions made by a military court, called a court-martial. This means the President cannot ask someone else to do this important job for them.
Contents
What Happened Before the Case?
Benjamin Piatt Runkle was a brave soldier who fought in the American Civil War. He was even hurt during the Battle of Shiloh. After the war, from 1867 to 1870, he worked for the Freedmen's Bureau in Kentucky. His job was to handle money, like a disbursing officer.
In 1870, Runkle was put on the retired list as a major, but he kept working. Later, he was arrested and faced a military trial, a court-martial. The court found him guilty of acting improperly and breaking rules. They decided he should be dismissed from the army, pay a fine, and go to prison.
The Secretary of War, W. W. Belknap, looked at the court's decision in 1873. He approved Runkle's conviction. However, because Runkle had served in the war and was wounded, the Secretary used the President's power to be merciful. He removed the fine and prison sentence. But Runkle was still dismissed from the army.
At that time, if an officer was dismissed from the army during peacetime, the President had to personally confirm the decision. The order dismissing Runkle did not clearly show that President Ulysses S. Grant had confirmed it himself.
Runkle's Petition to the President
On the very day he was dismissed, Runkle asked President Grant to review his case. He argued that his dismissal had not been properly confirmed by the President. President Grant sent Runkle's request to the Judge Advocate General (a top military lawyer) for review.
President Grant left office without making a final decision on Runkle's case. When President Rutherford B. Hayes became President, he took up Runkle's petition as unfinished business. President Hayes then issued an order disagreeing with Runkle's conviction. This order canceled the 1873 decision that had dismissed Runkle.
President Hayes's order from August 4, 1877, explained the whole situation:
EXECUTIVE MANSION, WASHINGTON, August 4, 1877.
In the Matter of the Application of Major Benjamin P. Runkle, U. S. Army, (retired.)
The record of official action heretofore taken in the premises shows the following facts, to-wit: First. That on the fourteenth of October, 1872, Major Runkle was found guilty by court-martial upon the following charges, to-wit: 'Charge 1. Violation of the act of congress approved March 2, 1863, c. 67, 1. Charge 2. Conduct unbecoming an officer and a gentleman.' Second. That on the sixteenth of January 1873, W. W. Belknap, then secretary of war, approved the proceedings of said court, and thereupon caused general order No. 7, series of 1873, to issue from the war department, by which it was announced that Major Benjamin P. Runkle was cashiered from the military service of the United States. Third. That subsequent to the date of said general order No. 7, to-wit, on the sixteenth day of January 1873, Major Runkle presented to the president a petition, setting forth that the proceedings of said court had not been approved by the president of the United States, as required by law; that said conviction was unjust; that the record of said proceedings was not in form or substance sufficient in law to warrant the issuing of said order; and asking the revocation and annulment of the same. Fourth. That, in pursuance of this petition, the record of the official action theretofore had in the premises was, by direction of the president, Ulysses S. Grant, referred to the judge advocate general of the United States army for review and report. Fifth. That thereupon the judge advocate general reviewed the case, and made his report thereon, in which it is reported and determined, among other things, that, in the proceedings had upon the trial of the case by said court, 'it is nowhere affirmatively established that he (Major Runkle) actually appropriated any money to his own use.' It also appears in said report that the conviction of said Runkle, upon charge one as aforesaid, is sustained upon the opinion that sufficient proof of the crime of embezzlement on the part of the accused was disclosed by the evidence before the court. And with respect to charge two no reference to the same is made in said report, except to deny the sufficiency of the evidence in the case, for a conviction upon the fourteenth specification thereof; and it is to be observed that the thirteen remaining specifications under this charge are identical with the thirteen specifications under charge one. The judge advocate general further finds and determines in said report as follows, to-wit: 'For alleged failures to pay, or to pay in full,' on the part of the subagents, 'I am of the opinion that the accused cannot justly be held liable.' Sixth. That no subsequent proceedings have been had with reference to said report, and that the said petition of said Runkle now awaits further and final action thereon. Whereupon, having caused the said record, together with said report, to be laid before me, and having carefully considered the same, I am of opinion that the said conviction is not sustained by the evidence in the case, and the same, together with the sentence of the court thereon, are hereby disapproved; and it is directed that said order No. 7, so far as it relates to said Runkle, be revoked.—R. B. HAYES.
Because of President Hayes's order, Runkle started receiving his retirement pay again. He received pay for the time after Hayes's order and also back pay for the time he had been dismissed. In 1882, Runkle asked for even more pay, called longevity pay. This request went to a special court called the Court of Claims. There, the government argued that President Hayes did not have the right to cancel the 1873 order dismissing Runkle. This disagreement led to the Supreme Court case.
The Supreme Court's Decision
The Supreme Court, led by Chief Justice Waite, made an important decision. They looked at all the facts and concluded that it was not clear if President Grant had ever truly approved Runkle's court-martial decision. The law at the time required the President's personal approval for such dismissals.
The Court said that because it wasn't clear if the President had personally approved the dismissal, Runkle was never legally removed from the army. This meant he was entitled to all his pay, including the longevity pay he was asking for.
The Court also made it clear that while the President doesn't have to sign every document, the approval of a court-martial decision must clearly show it came from the President's own judgment. It cannot just be a general order from a department that might not have gotten the President's personal attention. The fact that the order was the President's decision should not be left to guessing.
The Supreme Court overturned the Court of Claims' decision, sending the case back for further action based on their ruling.
Later Developments
Later Supreme Court cases, United States v. Fletcher (1893) and Bishop v. United States (1905), seemed to say that the Runkle decision was very unusual. They suggested that the special circumstances in Runkle's case meant it wasn't a good example for other cases.
However, a law professor named Joshua Kastenberg points out that in 1958, the Supreme Court case Harmon v. Brucker (1958) supported a main idea from Runkle, even though it didn't mention Runkle directly. This idea is that the President and the Department of Defense must follow their own rules. This rule also applies to government jobs outside the military. So, Runkle is still an important part of military law. It also means the President must follow the laws about military courts.
See also
