Edmond v. United States, 520 U.S. 651

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Table of Contents

Facts of the Case
Legal Questions of the Case
Case Decision and Legal Rationale for the Decision
Conclusion
Reference

The Edmond v. United States, 520 U.S. 651 (1997) case was decided in 1996 following a petition by Steven Edmond against the United States Court of Appeal. The case was filed in the Supreme Court, which held court hearings and gave the final ruling after several constitutional considerations. The legal parties of the case include Edmond, the petitioner, and the United States as the defendant. The court followed controversy over the constitutionality of the appointment clause in appointing military judges under the United States Court of Appeal for Armed Forces (CAAF). This essay explores the facts, issues, the court’s decisions, and the reasoning behind the ruling.

Facts of the Case

Edmond, a cocaine distributor, filed Edmond vs. the United States petitioning against the United States CAAF ruling. The petitioner was convicted by military judges for the distribution of cocaine, and he filed the case arguing that the military justice system did not have the institutional authority to preside over and decide his case. The Coast Guard Court of Criminal Appeals presided over and decided the case, which the United States Court of Appeals reviewed for the Armed Forces. The petitioner claimed that the Coast Guard Court of Criminal Appeals officials were appointed improperly and lacked the authority to sentence him (Edmond v. United States, 1997). The Secretary of Transportation appointed officials who had no authority over judicial matters. Further, judges from the United Nations CAAF acted outside their martial law jurisdiction by convicting a civilian, which violated the appointment clause. The supreme court presided over the case and was decided in June 1997, holding Edmond’s argument that the court tribunal that presided over his case was invalid.

Legal Questions of the Case

The primary question of the case was whether officers who sit on the United States CAAF review are constitutionally credible to preside over and rule cases against civilians. The conviction by the military judges was proper. The legal challenge was a constitutional issue under the appointments clause of the United States. According to the plaintiff, the judges who convicted him violated the appointment clause since their authority was limited to martial law. Being a civilian, Edmond argued that his case was supposed to be held in a civilian court and judges instead of the military judicial system because it is unconstitutional to convict a civilian according to military laws. Therefore, the court of appeal presented the case to the supreme court to validate whether the conviction was valid or whether the judges had acted outside their jurisdiction, violating the plaintiff’s constitutional right.

Case Decision and Legal Rationale for the Decision

The case was ruled in favor of Edmond over unfair judgment. It was unanimously decided at a 5-4 decision where the supreme court held that appointing military judges under CAAF violates the appointment clause allowing the president to appoint officials with consent from the senate. The supreme court claimed that the officials violated the appointment clause under the constitution despite being appointed by the president with consent from the senate (Edmond v. United States, 1997). The reasoning behind the court’s decision was that the military judges were “inferior officials” appointed under the appointment clause. According to the court, the appointment clause appoints officers in ranks, including principal officers and subordinates. Principal officers have considerable authority to make decisions in the United States, unlike the subordinates, whose power is limited to specific areas. Therefore, the military judges were regarded as inferior making them unsuitable for making decisions on behalf of the government. The supreme court stated that the military Judge’s authority was limited to making decisions within their jurisdiction, the military service system. Other judicial duties outside the military are inappropriate and cannot be held in case of convictions. Thus, the judgment could not hold since the judges were unqualified to pass a ruling under the United States constitution.

The court’s ruling was concurred by Justice David Souter, expressing his agreement with the court’s decision. The Judge agreed with the majority’s decision providing additional arguments to support the ruling. Souter emphasized the importance of separating constitutional power and different roles held by the judiciary principles. The Judge stated that the primary issue of the case was whether the military judges had violated the appointment clause to validate their ruling (Edmond v. United States, 1997). He acknowledged that the officials had violated the clause since the appointment did not give the officials significant power and discretion to act on behalf of the government. Additionally, military judges are unique from civilian judges, and their power is limited to martial law in the military justice system. Therefore, it was constitutionally unlawful to rule over a civilian case. Souter concluded that the presidential authority to appoint military judges implicates the appointment clause because a judge’s authority and duty are significant to require recognition in all sectors. Thus, the constitution should emphasize the importance of power separation considering the Appointment Clause.

Conclusion

Edmond vs. the United States dealt with a constitutional issue regarding military judges appointed under the appointment clause. The petitioner, Edmond, argued that his case was presided over and decided by improperly appointed judges. Thus, the conviction was invalid constitutionally. The supreme court held the petitioner’s claim and ruled against the United Nations CAAF because the officials had violated the appointment clause. Military officials appointed by the president through senate approval are regarded as inferior officials who cannot act on behalf of the government. Additionally, the military justice system does not apply to civilians making the verdict unconstitutional. Therefore, the case demonstrated the separation of power in different branches of the government, emphasizing the importance of following the constitution when exercising authority.

Reference

Edmond v. United States, 520 U.S 651 (1997), JUSTIA U.S Supreme Court (The Supreme Court 1997). Web.

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Edmond v. United States, 520 U.S. 651

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