Taylor v. Beckham

Taylor v. Beckham, 178 U.S. 548 (1900), was a case heard before the Supreme Court of the United States on April 30 and May 1, 1900, to decide the outcome of the disputed Kentucky gubernatorial election of 1899 . The litigants were Republican gubernatorial candidate William S. Taylor and Democratic lieutenant gubernatorial candidate J. C. W. Beckham . In the November 7, 1899, election, Taylor received 193,714 votes to Democrat William Goebel 's 191,331. This result was certified by a 2–1 decision of the state's Board of Elections. Goebel challenged the election results on the basis of alleged voting irregularities , and the Democrat-controlled Kentucky General Assembly formed a committee to investigate Goebel's claims. Goebel was shot on January 30, 1900, one day before the General Assembly approved the committee's report declaring enough Taylor votes invalid to swing the election to Goebel. As he lay dying of his wounds, Goebel was sworn into office on January 31, 1900. He died on February 3, 1900, and Beckham ascended to the governorship.

Claiming the General Assembly's decision was invalid, Taylor sued to prevent Beckham from exercising the authority of the governor's office. Beckham countersued Taylor for possession of the state capitol and governor's mansion . The suits were consolidated and heard in Jefferson County circuit court , which claimed it had no authority to interfere with the method of deciding contested elections prescribed by the state constitution , an outcome that favored Beckham. The Kentucky Court of Appeals upheld the circuit court's decision on appeal and rejected Taylor's claim that he had been deprived of property without due process by stating that an elective office was not property and thus not protected by the Fourteenth Amendment .

The injection of Taylor's claim under the Fourteenth Amendment gave him grounds to appeal the decision to the U.S. Supreme Court. In a majority opinion delivered by Chief Justice Melville Fuller , the Supreme Court also rejected Taylor's claim to loss of property without due process and thus refused to intervene on Taylor's behalf, claiming that no federal issues were in question and the court lacked jurisdiction. Justices Gray , White , Shiras , and Peckham concurred with the majority opinion. Justice Joseph McKenna concurred with the decision to dismiss, but expressed reservations about the determination that an elected office was not property. Justice David J. Brewer , joined by Justice Henry B. Brown , contended that the Supreme Court did have jurisdiction, but concurred with the result in favor of Beckham. Kentuckian John Marshall Harlan authored the lone dissent from the majority opinion, claiming that the court did have jurisdiction and should have found in favor of Taylor based on his claim of loss of property without due process. He further argued that elective office fell under the definition of "liberty" as used in the Fourteenth Amendment and was protected by due process.

Contents

• 1 Background

  • 1.1 History

  • 1.2 Lower court decisions

• 2 Supreme Court

  • 2.1 Opinion of the Court

  • 2.2 Dissent of Justice Brewer

  • 2.3 Dissent of Justice Harlan

• 3 Subsequent developments

• 4 Notes

• 5 References

• 6 External links

Background

(https://en.wikipedia.org/w/index.php?title=Taylor_v._Beckham&action=edit&section=1 "Edit section: Background")

History

(https://en.wikipedia.org/w/index.php?title=Taylor_v._Beckham&action=edit&section=2 "Edit section: History")

See also: Kentucky gubernatorial election, 1899

In 1898, the Kentucky General Assembly enacted a law which created a Board of Election Commissioners, appointed by the General Assembly, who were responsible for choosing election commissioners in all of Kentucky's counties . The board was empowered to examine election returns and certify the results. The power to decide the outcome of disputed elections remained with the General Assembly under Section 153 of the state constitution . The law was commonly referred to as the Goebel Election Law, a reference to its sponsor, President Pro Tempore of the Kentucky Senate William Goebel . Because the General Assembly was heavily Democratic and Goebel was considered a likely Democratic aspirant for the governorship in the 1899 election , the law was attacked as blatantly partisan and self-serving. Republicans organized a test case against the law, but the Kentucky Court of Appeals upheld it as constitutional.

Goebel secured the Democratic nomination for governor at a contentious nominating convention. Despite the nominations of two minor party candidates – including that of former governor John Y. Brown by a dissident faction of Democrats – the race centered on Goebel and his Republican opponent, Attorney General William S. Taylor . The results of the election were too close to call for several days. Before the official results could be announced, charges of voting irregularities began. In Nelson County , 1,200 ballots listed the Republican candidate as "W. P. Taylor" instead of "W. S. Taylor"; Democrats claimed these votes should be invalidated. In Knox and Johnson counties, voters complained of "thin tissue ballots" that allowed the voter's choices to be seen through them. In the city of Louisville , Democrats charged that the militia had intimidated voters there and that the entire city's vote should be invalidated.

[William S. Taylor](https://en.wikipedia.org/wiki/Willia

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