Introduction
Humphrey’s Executor V. United States and Myers V. United States are similar cases. The Humphrey’s case builds upon precedents set by the Myers case. The Humphrey’s case and the Myers case test the powers of the president of the United States to hire and fire individuals at will. Cases will be examined explained based upon stare decisis ( Latin for “to stand by a decision,” the doctrine that a trial court is bound by appellate court decisions (precedents) on a legal question which is raised in the lower court. Reliance on such precedents is required of trial courts until such time as an appellate court changes the rule, for the trial court cannot ignore the precedent (even when the trial judge believes it is “bad law”)1.
Myers V. United States 272 US 52
This case was argued on December 5th 1923, reargued on April 13-14th 1925, and decided upon on October 25, 1926. The ruling by the Supreme Court of the United States stated that the President has the power to remove from office those executive branch officials without the approval of the U.S. Senate. This case was brought forward to the Supreme Court by Frank Myers who believed that he had been removed from office illegally by President Woodrow Wilson. Myer based his complaint upon an 1876 law that states that postmasters can only be removed by the President with the advice and consent of the Senate.
Chief Justice William H. Taft identified this case as a Constitutional issue. Taft, and the Majority, ruled that the Constitution allows the President to dismiss members of his staff who are considered an extension of the President’s power and authority. Myers, in the position of First Class Postmaster of Portland, Oregon, was considered a member of Woodrow Wilson’s executive staff and was subject to termination by the President.
Dissents by Supreme Court Justices argued that because there was no mention of this Presidential Power over executive staff in the Constitution, then the ruling giving the President the authority to remove executive staff was unconstitutional.
Humphrey’s Executor V. United States 295 US
Humphrey’s Ex’r V. United States was argued on May 1st 1935 and decided o May 27th of 1935. This case was brought to the court by a disgruntled William Humphrey who argued that he had been removed from his posting as a member of the Federal Trade Commission unfairly. Humphrey had been appointed to his post by then President Hoover. After President Roosevelt took office he requested that Humphrey submit his resignation. Roosevelt requested the resignation because Humphrey’s did not agree with Roosevelt’s New Deal plan. Roosevelt felt that the New Deal could only move forward with those who shared his vision of the New Deal. This included those appointed by Hoover. Those who did not share Roosevelt’s position, like Humphrey, were asked to resign.
Humphrey refused to resign resulting in the order from Roosevelt that removed him from office effective October 7, 1933. This order effectively dismissed Humphrey from his appointment as Commissioner of the Federal Trade Commission. Humphrey’s Executor argued for Humphrey’s reinstatement and back wages earned from October 1933 until his death in 1934.
Argument for this case included the case of Myers V. United States and the case of Marbury V. Madison. The ruling in this case included identifying the position as either an executive office or a quasi-legislative office. If the position was found to be an executive office (such as Myers V. United States) then the President had the authority to remove Humphrey. If the position was found to be quasi-legislative then Roosevelt could not remove Humphrey. The Supreme Court ruled in favor of Humphrey based upon identifying the position he held as a legislative position.
Conclusion
Both Myers V. United States and Humphrey V. United States were judged based upon similar circumstances. Myers’ position was identified as an executive position and Humphrey’s position was identified as a legislative position. The Supreme Court ruled that the President had the power to remove someone from an executive position but not from a legislative position. Thus Myers could be removed and Humphrey could not be removed. Humphrey could only be removed by statutory conditions defined by Congress.
References
American Psychological Association (2001). Publication manual of the American Psychological Association (5th ed.). Washington, DC: American Psychological Association.
U.S. Supreme Court (1935) Humphrey’ EX’r V. United States, 295 U.S. 602 (1935). Web.
U.S. Supreme Court (1926). Myers V. United States, 272 U.S. 52 (1926). Web.