## Facts

- Mail contractors (Stokes, Richard C. Stockton, Lucius W. Stockton, and Moore) performed mail-transportation contracts and received credits and payments approved by a prior Postmaster General.
- After a change in office, Postmaster General Amos Kendall reexamined the accounts, withdrew prior credits, and recharged the contractors for amounts already paid.
- Congress enacted a special statute (July 2, 1836) directing the Solicitor of the Treasury to settle and adjust the contractors’ claims for extra services based on equitable principles.
- The statute further directed the Postmaster General to credit the contractors with whatever sums the Solicitor decided were due.
- The Solicitor decided an amount was due and reported it to Kendall; Kendall credited only part and refused to enter the remainder.
- The contractors sought a writ of mandamus in the federal Circuit Court for the District of Columbia to compel Kendall to enter the full credit.
- The circuit court issued a peremptory mandamus, and Kendall sought review in the Supreme Court by writ of error.

## Issues

1. Whether a federal court may issue mandamus to compel an executive officer to perform an act required by statute without violating separation of powers.
2. Whether the statute imposed a ministerial duty on the Postmaster General (enforceable by mandamus) or left discretion insulated from judicial compulsion.
3. Whether the Circuit Court for the District of Columbia had authority to issue mandamus against the Postmaster General in these circumstances.

## Decision

- The Supreme Court affirmed the peremptory mandamus.
- The Court held that the statute required the Postmaster General to credit the contractors in the amount determined by the Solicitor of the Treasury.
- Because the duty was ministerial and nondiscretionary, mandamus was an appropriate remedy.
- Compelling performance of this statutory duty did not intrude on executive functions or create a conflict between the judicial and executive branches.
- The Circuit Court for the District of Columbia had authority to issue mandamus to enforce a clear legal right and a duty specifically imposed by law.

## Legal Principles

- Mandamus may issue to compel a federal executive officer to perform a ministerial act when the law defines the duty with sufficient certainty to leave no room for discretion.
- Judicial enforcement of a statutory ministerial duty does not violate separation of powers because it enforces legislative command rather than directing executive judgment.
- When Congress assigns decision-making authority to one officer (here, the Solicitor’s settlement and determination) and directs another officer to implement that decision, the implementing officer has no lawful discretion to refuse compliance.
- A court may treat mandamus as a civil remedy to enforce a specific legal right created by statute where the officer’s duty is plainly prescribed.

## Conclusion

The Court held that Congress validly imposed a nondiscretionary duty on the Postmaster General to enter credits fixed through a statutory settlement mechanism, and that federal courts may compel such ministerial compliance by mandamus without infringing executive authority.


Kendall v. United States ex rel. Stokes, 37 U.S. (12 Pet.) 524 (1838)