Ex parte Curtis
Ex parte Curtis, 106 U.S. 371, is an 8–1 ruling by the United States Supreme Court that the Act of August 15, 1876 was a constitutional exercise of the enumerated powers of the United States Congress under Article One of [the United States Constitution#Section 8: Powers of Congress|Article I, Section 8] of the United States Constitution.
The petitioner had been convicted of receiving money for political purposes in violation of the Act. The petitioner asked the Supreme Court for a writ of habeas corpus.
Majority opinion
wrote the opinion for the majority. The constitutional grounds under which the petitioner challenged the Act were not discussed by the Court. Waite noted that Congress had a lengthy history of passing laws restricting the rights and privileges of civil servants, and the constitutionality of such laws had never before been challenged.Next, Waite affirmed that Article I, Section 8 of the Constitution clearly gave Congress the power to determine for itself what was proper in the realm of reining in political corruption:
Waite refused to pass judgment on the validity of the writ of habeas corpus, concluding that the Supreme Court's "jurisdiction is limited to the single question of the power of the court to commit the prisoner for the act of which he has been convicted."
Dissenting opinion
dissented. He concluded that the Act impermissibly infringed on First Amendment to the [United States Constitution|First Amendment] rights of freedom of speech and freedom of association:Justice Bradley also concluded that the Act was overbroad and that the same positive ends could have been achieved by alternative, narrower means.
Assessment
One of the interesting aspects of the majority's decision is that it believed Congress prohibited not civil servants from making political donations on their own but making such donations through their supervisors. Justice Bradley dissented, in part, by arguing that the law banned even voluntary contributions made through superiors.At least one commentator has concluded that Ex parte Curtis is still "good law."