1. United States v. Klein, (1872)
2. Facts: Klein was pardoned by the president for aiding in the civil war rebellion. A statute existed that would allow persons who did not aid in the rebellion to recover land seized from them in the Reconstruction. Previous case law had held that a presidential pardon was conclusive proof that a person had not committed the crime.
3. Procedural Posture: A new statute was enacted by Congress while the Klein case was pending appeal, reversing the previous tradition of a pardon being proof of non-participation, and in fact making it conclusive proof of actual participation. In addition, the statute purported to remove federal court jurisdiction for all such claims arising from pardons.
4. Issue: Whether Congress has the constitutional power to enact a statute which limits the jurisdiction of the federal courts, particularly the Supreme Court, when, by limiting said jurisdiction would dictate the outcome of a particular case.
5. Holding: No.
6. ∏ Argument: Congress has the power under Article III to limit the appellate jurisdiction of the federal courts because of the specific language “with such exceptions...as the Congress shall make.”
7. ∆ Argument: Congress does not have the power to dictate the outcome of any particular case because such would be contrary to the separation of powers structure of the Constitution.
8. Majority Reasoning: The statute removing jurisdiction in this instance was unconstitutional because it was only “a means to an end,” to affect the outcome of this particular case. Dismissing the appeal would allow Congress to prescribe the judgments of the Supreme Court directly. The statute prescribed how the court should decide an issue of fact, and it denied effect to a Presidential Pardon, thus violating the separation of powers.
