## Facts

- Augustus D. Juilliard sold and delivered 100 bales of cotton to Thomas S. Greenman for $5,122.90, payable in cash on delivery.
- Greenman tendered $22.50 in gold coin, $0.40 in silver coin, and two United States legal-tender notes ($5,000 and $100) for the balance.
- The notes had been issued under the Legal Tender Acts of 1862 and 1863, redeemed in gold after January 1, 1879, and reissued under the Act of May 31, 1878 requiring redeemed notes to be reissued and kept in circulation.
- Juilliard refused the notes for the $5,100 balance and demanded payment in coin.

## Issues

1. Whether the Act of May 31, 1878 required redeemed and reissued United States notes to retain legal-tender status for private debts.
2. Whether Congress has constitutional power, in peacetime as well as wartime, to make United States treasury notes legal tender in payment of private debts.

## Decision

- The Supreme Court affirmed judgment for Greenman.
- The Court held that, under the Act of May 31, 1878, redeemed and reissued United States notes remain legal tender for private debts.
- The Court held that Congress has constitutional authority to make U.S. notes legal tender in payment of private debts in time of peace as well as in time of war.
- Justice Field dissented, arguing the Constitution’s borrowing and coining powers do not include forcing private creditors to accept paper in place of coin.

## Legal Principles

- Congress’s powers to borrow money, to coin money and regulate its value, and to enact laws necessary and proper to execute those powers permit creation and maintenance of a national paper currency with legal-tender quality.
- Legal-tender status validly attached to United States notes continues upon redemption and reissue when Congress directs that such notes be paid out again and kept in circulation.
- The constitutional power to make U.S. notes legal tender is not limited to wartime emergencies; it may be exercised in peacetime as part of Congress’s permanent monetary and fiscal authority.

## Conclusion

The Court upheld Congress’s authority to maintain reissued United States notes as legal tender and confirmed that federal power to make paper money legal tender for private debts extends to peacetime as well as wartime.


Juilliard v. Greenman, 110 U.S. 421 (1884)