## Facts

- Congress enacted the Invalid Pensions Act of 1792, directing federal circuit courts to receive disabled veterans’ pension applications, take evidence, assess disability, and transmit recommendations to the Secretary of War.
- The Act allowed the Secretary of War and Congress to revise, suspend, or decline the courts’ recommended awards.
- Federal circuit courts in New York, Pennsylvania, and North Carolina refused to carry out these responsibilities as courts and sent written objections to the President.
- Attorney General Edmund Randolph sought a writ of mandamus in the Supreme Court to compel the Circuit Court for the District of Pennsylvania to proceed on William Hayburn’s pension petition.
- The Supreme Court rejected Randolph’s initial attempt to proceed without a specific applicant; Randolph then proceeded on Hayburn’s behalf.
- The Supreme Court continued the matter to a later Term, and Congress subsequently reassigned the pension-processing duties away from the circuit courts, mooting the dispute before a merits judgment issued.

## Issues

1. Whether Congress may require Article III courts, acting in their judicial capacity, to perform administrative pension-processing tasks.
2. Whether a statutory scheme that makes a court’s determinations subject to revision by the executive and legislature is consistent with Article III judicial power.
3. Whether the Supreme Court could issue mandamus to compel a lower federal court to carry out duties assigned by Congress under the pension statute.

## Decision

- The Supreme Court did not issue a merits decision on the constitutionality of the 1792 Act.
- The Court declined to allow the Attorney General to proceed *ex officio* without an identified injured party.
- After the motion was reframed on behalf of William Hayburn, the Court continued the case; Congress then amended the law, removing the challenged duties from the circuit courts.
- The constitutional questions were left unresolved by formal judgment, but the circuit judges’ written objections became influential statements about limits on judicial power.

## Legal Principles

- Article III courts may not be compelled, in their official judicial capacity, to perform duties that are administrative rather than adjudicative.
- A statutory arrangement that renders a court’s determinations merely recommendatory and subject to revision by executive or legislative officials is incompatible with the independence of the judiciary.
- Separation of powers limits Congress’s ability to assign governmental functions to federal courts outside the exercise of judicial power.
- Federal judges may, as individuals (not as courts), be capable of performing certain nonjudicial functions, but that does not convert those functions into Article III adjudication.

## Conclusion

Hayburn’s Case ended without a Supreme Court merits ruling because Congress reassigned the pension duties, but it is remembered for the circuit judges’ objections: Congress cannot use Article III courts as administrative agents whose determinations are reviewable by the political branches.


Hayburn’s Case, 2 U.S. (2 Dall.) 409 (1792)