During the American Revolution, the state of Georgia passed a law that sequestered debts owed to British creditors. The Treaty of Paris between the United States and Great Britain asserted the validity of debts held by creditors on both sides. Samuel Brailsford, a British subject and holder of such a debt, attempted to recover from Georgia resident James Spalding. The case was filed directly in the United States Supreme Court, rather than in a lower court, under its constitutionally defined original jurisdiction.[2] Georgia intervened in the Supreme Court, claiming that the debt was owed instead to the state. Brailsford was joined by Messrs. Hopton and Powell, residents of South Carolina, who were partners in the debt. Because the Court was trying a common law dispute, it impaneled a jury for the case.
Decisionedit
The Court concluded that the sequestration law did not transfer the debt interest to the state. After being advised of that opinion, the jury found for the defendants.[1]
Power of juriesedit
Chief Justice Jay's instructions to the jury have attracted much interest surrounding their implications for jury nullification. Jay noted it as a "good old rule" that juries should judge questions of fact while deferring to the court on questions of law; yet he observed that the jury could, if it chose, judge both to arrive at a decision.[1] As mentioned, the jury neither challenged the Court's conclusions of law nor needed to examine the facts, which the parties had agreed upon.[3]
Subsequent jurisprudence has tended to discount the Brailsford court's view. In United States v. Morris (1851), Justice Benjamin Robbins Curtis commented on the apparent inconsistency of Jay's recorded instructions, going so far as to suggest that the record was inaccurate and, in any case, not in line with recent English or American law. Sparf v. United States (1895) repeated Curtis's doubts and found that federal courts had no obligation to give similar instructions.[4]
Stanford Law School fellow Lochlan F. Shelfer has examined the case record in depth. He notes that the jury was a special jury, drawn from a pool of merchants informed on matters of law relevant to the case. Their relation to the court, then, was different from that of a typical fact-finding jury. Shelfer concludes that the instructions were neither anomalous nor an endorsement of jury nullification but rather reflected the immaturity of American merchant law and the reliance of courts on experts.[3]
^ abcGeorgia v. Brailsford, 3U.S. (3 Dall.) 1 (1794).
^ abShelfer, Lochlan F. (October 2013). "Special Juries in the Supreme Court". Yale Law Journal. 123 (1): 208–252. from the original on June 30, 2017. Retrieved October 2, 2018.
^ abLochlan F. Shelfer, Special Juries in the Supreme Court, 123 Yale. L.J. 208 (2013). [1]
Text of Georgia v. Brailsford, 3U.S. (3 Dall.) 1 (1794) is available from:CornellGoogle ScholarJustiaLibrary of CongressOpenJurist
February 16, 2024
georgia, brailsford, 1794, other, rulings, this, case, georgia, brailsford, disambiguation, georgia, brailsford, dall, 1794, early, united, states, supreme, court, case, holding, that, debts, sequestered, declared, forfeit, states, during, american, revolution. For other rulings in this case see Georgia v Brailsford disambiguation Georgia v Brailsford 3 U S 3 Dall 1 1794 was an early United States Supreme Court case holding that debts sequestered but not declared forfeit by states during the American Revolution could be recovered by bondholders 1 It is the only reported jury trial in the history of the Supreme Court 2 Georgia v BrailsfordSupreme Court of the United StatesArgued February 4 7 1794Decided February 7 1794Full case nameState of Georgia v Samuel Brailsford amp othersCitations3 U S 1 more 3 Dall 1 1 L Ed 483 1794 U S LEXIS 102HoldingSequestration of debts by states during the American Revolution did not permanently vest those debts in the states Court membershipChief Justice John Jay Associate Justices James Wilson William CushingJohn Blair Jr James IredellWilliam PatersonCase opinionMajorityJay joined by unanimous Contents 1 Background 2 Decision 3 Power of juries 4 See also 5 References 6 External linksBackground editDuring the American Revolution the state of Georgia passed a law that sequestered debts owed to British creditors The Treaty of Paris between the United States and Great Britain asserted the validity of debts held by creditors on both sides Samuel Brailsford a British subject and holder of such a debt attempted to recover from Georgia resident James Spalding The case was filed directly in the United States Supreme Court rather than in a lower court under its constitutionally defined original jurisdiction 2 Georgia intervened in the Supreme Court claiming that the debt was owed instead to the state Brailsford was joined by Messrs Hopton and Powell residents of South Carolina who were partners in the debt Because the Court was trying a common law dispute it impaneled a jury for the case Decision editThe Court concluded that the sequestration law did not transfer the debt interest to the state After being advised of that opinion the jury found for the defendants 1 Power of juries editChief Justice Jay s instructions to the jury have attracted much interest surrounding their implications for jury nullification Jay noted it as a good old rule that juries should judge questions of fact while deferring to the court on questions of law yet he observed that the jury could if it chose judge both to arrive at a decision 1 As mentioned the jury neither challenged the Court s conclusions of law nor needed to examine the facts which the parties had agreed upon 3 Subsequent jurisprudence has tended to discount the Brailsford court s view In United States v Morris 1851 Justice Benjamin Robbins Curtis commented on the apparent inconsistency of Jay s recorded instructions going so far as to suggest that the record was inaccurate and in any case not in line with recent English or American law Sparf v United States 1895 repeated Curtis s doubts and found that federal courts had no obligation to give similar instructions 4 Stanford Law School fellow Lochlan F Shelfer has examined the case record in depth He notes that the jury was a special jury drawn from a pool of merchants informed on matters of law relevant to the case Their relation to the court then was different from that of a typical fact finding jury Shelfer concludes that the instructions were neither anomalous nor an endorsement of jury nullification but rather reflected the immaturity of American merchant law and the reliance of courts on experts 3 See also editJury nullification in the United StatesReferences edit a b c Georgia v Brailsford 3 U S 3 Dall 1 1794 a b Shelfer Lochlan F October 2013 Special Juries in the Supreme Court Yale Law Journal 123 1 208 252 Archived from the original on June 30 2017 Retrieved October 2 2018 a b Lochlan F Shelfer Special Juries in the Supreme Court 123 Yale L J 208 2013 1 Sparf v United States 156 U S 51 1895 External links editText of Georgia v Brailsford 3 U S 3 Dall 1 1794 is available from Cornell Google Scholar Justia Library of Congress OpenJurist Retrieved from https en wikipedia org w index php title Georgia v Brailsford 1794 amp oldid 1175142760, wikipedia, wiki, book, books, library,
