Samuel Freeman Miller
Encyclopedia
Samuel Freeman Miller was an associate justice of the United States Supreme Court from 1862–1890. He was a physician and lawyer.
, Miller was the son of yeoman farmers. He earned a medical degree in 1838 from Transylvania University
, Lexington, Kentucky
. While practicing medicine for a decade, he studied the law on his own and was admitted to the bar in 1847. Favoring the abolition
of slavery
, which was prevalent in middle Kentucky, he supported the Whigs
in Kentucky
.
, a state more amenable to his views on slavery. Active in Hawkeye politics, he supported Abraham Lincoln
in the 1860 election. Lincoln nominated Miller to the Supreme Court on July 16, 1862, after the beginning of the American Civil War
. His reputation was so high that Miller was confirmed half an hour after the Senate received notice of his nomination.
His opinions strongly favored Lincoln's positions, and he upheld his wartime suspension of habeas corpus
and trials by military commission. After the war, his narrow reading of the Fourteenth Amendment
—he wrote the opinion in the Slaughterhouse Cases
—limited the effectiveness of the amendment. Miller wrote the majority opinion in Bradwell v. Illinois
, which held that the right to practice law was not constitutionally protected under the Privileges or Immunities Clause
of the Fourteenth Amendment.
He later joined the majority opinions in United States v. Cruikshank
and the Civil Rights Cases
, holding that the amendment did not give the United States government the power to stop private, as opposed to state-sponsored, discrimination against blacks. In Ex Parte Yarbrough, 110 U.S. 651 (1884), however, Miller held that the federal government had broad authority to act to protect black voters from violence by the Ku Klux Klan
and other private groups. Miller also supported the use of broad federal power under the Commerce Clause
to trump state regulations, as in Wabash v. Illinois.
In all, Miller wrote twice the number of opinions as any of his colleagues on the Court, leading future Chief Justice
William Rehnquist
to describe him as "very likely the dominant figure" on the Court in his time. When Chief Justice Salmon P. Chase
died in 1873, attorneys and law journals across the country lobbied for Miller to be appointed to succeed him, but President Ulysses Grant
was determined to appoint an outsider. (He ultimately chose Morrison Waite
.)
After the 1876 presidential election between Rutherford Hayes and Samuel Tilden, Miller served on the electoral commission that awarded the disputed electoral votes to the Republican Hayes. In the 1880s, his name was floated as a Republican candidate for president.
Miller, a religious liberal, belonged to the Unitarian
Church and served as President of the Unitarians' National Conference in 1884.
He died in Washington, D.C.
while still a member of the court. He is buried at Oakland Cemetery in Keokuk, Iowa
.
Early life and education
Born in Richmond, KentuckyRichmond, Kentucky
There were 10,795 households out of which 24.4% had children under the age of 18 living with them, 35.2% were married couples living together, 12.8% had a female householder with no husband present, and 48.6% were non-families. Of all households, 34.7% were made up of individuals and 8.8% had...
, Miller was the son of yeoman farmers. He earned a medical degree in 1838 from Transylvania University
Transylvania University
Transylvania University is a private, undergraduate liberal arts college in Lexington, Kentucky, United States, affiliated with the Christian Church . The school was founded in 1780. It offers 38 majors, and pre-professional degrees in engineering and accounting...
, Lexington, Kentucky
Lexington, Kentucky
Lexington is the second-largest city in Kentucky and the 63rd largest in the US. Known as the "Thoroughbred City" and the "Horse Capital of the World", it is located in the heart of Kentucky's Bluegrass region...
. While practicing medicine for a decade, he studied the law on his own and was admitted to the bar in 1847. Favoring the abolition
Abolitionism
Abolitionism is a movement to end slavery.In western Europe and the Americas abolitionism was a movement to end the slave trade and set slaves free. At the behest of Dominican priest Bartolomé de las Casas who was shocked at the treatment of natives in the New World, Spain enacted the first...
of slavery
Slavery
Slavery is a system under which people are treated as property to be bought and sold, and are forced to work. Slaves can be held against their will from the time of their capture, purchase or birth, and deprived of the right to leave, to refuse to work, or to demand compensation...
, which was prevalent in middle Kentucky, he supported the Whigs
Whig Party (United States)
The Whig Party was a political party of the United States during the era of Jacksonian democracy. Considered integral to the Second Party System and operating from the early 1830s to the mid-1850s, the party was formed in opposition to the policies of President Andrew Jackson and his Democratic...
in Kentucky
Kentucky
The Commonwealth of Kentucky is a state located in the East Central United States of America. As classified by the United States Census Bureau, Kentucky is a Southern state, more specifically in the East South Central region. Kentucky is one of four U.S. states constituted as a commonwealth...
.
Career
Miller moved to Keokuk, IowaKeokuk, Iowa
Keokuk is a city in the southeastern part of the U.S. state of Iowa and one of the county seats of Lee County. The other county seat is Fort Madison. The population was 11,427 at the 2000 census. The city is named after the Sauk Chief Keokuk, who is thought to be buried in Rand Park...
, a state more amenable to his views on slavery. Active in Hawkeye politics, he supported Abraham Lincoln
Abraham Lincoln
Abraham Lincoln was the 16th President of the United States, serving from March 1861 until his assassination in April 1865. He successfully led his country through a great constitutional, military and moral crisis – the American Civil War – preserving the Union, while ending slavery, and...
in the 1860 election. Lincoln nominated Miller to the Supreme Court on July 16, 1862, after the beginning of the American Civil War
American Civil War
The American Civil War was a civil war fought in the United States of America. In response to the election of Abraham Lincoln as President of the United States, 11 southern slave states declared their secession from the United States and formed the Confederate States of America ; the other 25...
. His reputation was so high that Miller was confirmed half an hour after the Senate received notice of his nomination.
His opinions strongly favored Lincoln's positions, and he upheld his wartime suspension of habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
and trials by military commission. After the war, his narrow reading of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
—he wrote the opinion in the Slaughterhouse Cases
Slaughterhouse Cases
The Slaughter-House Cases, were the first United States Supreme Court interpretation of the relatively new Fourteenth Amendment to the Constitution...
—limited the effectiveness of the amendment. Miller wrote the majority opinion in Bradwell v. Illinois
Bradwell v. Illinois
Bradwell v. State of Illinois, 83 U.S. 130 , was a United States Supreme Court case that solidified the narrow reading of the Privileges or Immunities Clause of the Fourteenth Amendment, and determined that the right to practice a profession was not among these privileges...
, which held that the right to practice law was not constitutionally protected under the Privileges or Immunities Clause
Privileges or Immunities Clause
The Privileges or Immunities Clause is Amendment XIV, Section 1, Clause 2 of the United States Constitution. It states:Along with the rest of the Fourteenth Amendment, this clause became part of the Constitution on July 9, 1868....
of the Fourteenth Amendment.
He later joined the majority opinions in United States v. Cruikshank
United States v. Cruikshank
United States v. Cruikshank, 92 U.S. 542 was an important United States Supreme Court decision in United States constitutional law, one of the earliest to deal with the application of the Bill of Rights to state governments following the adoption of the Fourteenth Amendment.-Background:On Easter...
and the Civil Rights Cases
Civil Rights Cases
The Civil Rights Cases, 109 U.S. 3 , were a group of five similar cases consolidated into one issue for the United States Supreme Court to review...
, holding that the amendment did not give the United States government the power to stop private, as opposed to state-sponsored, discrimination against blacks. In Ex Parte Yarbrough, 110 U.S. 651 (1884), however, Miller held that the federal government had broad authority to act to protect black voters from violence by the Ku Klux Klan
Ku Klux Klan
Ku Klux Klan, often abbreviated KKK and informally known as the Klan, is the name of three distinct past and present far-right organizations in the United States, which have advocated extremist reactionary currents such as white supremacy, white nationalism, and anti-immigration, historically...
and other private groups. Miller also supported the use of broad federal power under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
to trump state regulations, as in Wabash v. Illinois.
In all, Miller wrote twice the number of opinions as any of his colleagues on the Court, leading future Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
to describe him as "very likely the dominant figure" on the Court in his time. When Chief Justice Salmon P. Chase
Salmon P. Chase
Salmon Portland Chase was an American politician and jurist who served as U.S. Senator from Ohio and the 23rd Governor of Ohio; as U.S. Treasury Secretary under President Abraham Lincoln; and as the sixth Chief Justice of the United States Supreme Court.Chase was one of the most prominent members...
died in 1873, attorneys and law journals across the country lobbied for Miller to be appointed to succeed him, but President Ulysses Grant
Ulysses S. Grant
Ulysses S. Grant was the 18th President of the United States as well as military commander during the Civil War and post-war Reconstruction periods. Under Grant's command, the Union Army defeated the Confederate military and ended the Confederate States of America...
was determined to appoint an outsider. (He ultimately chose Morrison Waite
Morrison Waite
Morrison Remick Waite, nicknamed "Mott" was the seventh Chief Justice of the United States from 1874 to 1888.-Early life and education:...
.)
After the 1876 presidential election between Rutherford Hayes and Samuel Tilden, Miller served on the electoral commission that awarded the disputed electoral votes to the Republican Hayes. In the 1880s, his name was floated as a Republican candidate for president.
Miller, a religious liberal, belonged to the Unitarian
Unitarianism
Unitarianism is a Christian theological movement, named for its understanding of God as one person, in direct contrast to Trinitarianism which defines God as three persons coexisting consubstantially as one in being....
Church and served as President of the Unitarians' National Conference in 1884.
He died in Washington, D.C.
Washington, D.C.
Washington, D.C., formally the District of Columbia and commonly referred to as Washington, "the District", or simply D.C., is the capital of the United States. On July 16, 1790, the United States Congress approved the creation of a permanent national capital as permitted by the U.S. Constitution....
while still a member of the court. He is buried at Oakland Cemetery in Keokuk, Iowa
Keokuk, Iowa
Keokuk is a city in the southeastern part of the U.S. state of Iowa and one of the county seats of Lee County. The other county seat is Fort Madison. The population was 11,427 at the 2000 census. The city is named after the Sauk Chief Keokuk, who is thought to be buried in Rand Park...
.
Noteworthy opinions
- The Slaughter-House Cases, 83 U.S. 36 (1873)
- Murdock v. Memphis, 87 U.S. 20 Wall. 590 590 (1874)
- In re Burrus, 136 U.S. 586 (1890)
See also
- Justice Samuel Freeman Miller HouseJustice Samuel Freeman Miller HouseThe Justice Samuel Freeman Miller House in Keokuk, Iowa, United States is an Italianate style home that was built in 1859. It was listed on the National Register of Historic Places in 1972. The building is now operated as the Miller House Museum by the Lee County Historical Society...
, listed on the National Register of Historic Places in IowaNational Register of Historic Places listings in Lee County, IowaThis is a list of the National Register of Historic Places listings in Lee County, Iowa.This is intended to be a complete list of the properties and districts on the National Register of Historic Places in Lee County, Iowa, United States...