Myers v. United States

Following is the case brief for Myers v. United States, 272 U.S. 52 (1926)

Case Summary of Myers v. United States:

  • An 1876 federal law prohibited a first-, second-, or third-class postmaster from being removed from office without approval by the Senate.
  • President Woodrow Wilson removed first-class postmaster Myers without Senate approval.
  • Myers sought backpay, claiming that the President’s action was in violation of the law.
  • The Court of Claims dismissed Myers’ claim.
  • The U.S. Supreme Court affirmed the denial, holding that the President has the exclusive power to remove an executive branch officer under the Constitution.

Myers v. United States Case Brief

Statement of the Facts:

An 1876 federal law prohibited a first-, second-, or third-class postmaster from being removed from office without approval by the Senate.  Specifically, the statute states that “Postmasters of the first, second, and third classes shall be appointed and may be removed by the President with the advice and consent of the Senate.”

President Woodrow Wilson removed first-class postmaster Myers without Senate approval.  Myers sought backpay, claiming that the President’s action was in violation of the law.

Procedural History:

  • The Court of Claims dismissed Myers’ suit as out of time.
  • The U.S. Supreme Court agreed to hear the appeal.

Issue and Holding:

Does the President have the exclusive authority to remove executive branch officials without the approval of the Senate?  Yes.

Judgment:

The decision of the Court of Claims is affirmed.

Rule of Law or Legal Principle Applied:

The President has the exclusive power to remove executive branch officers without Senate approval.

Reasoning:

The Constitution expressly states that the President shall appoint executive branch officers with the advice and consent of the Senate.  The Constitution, however, is silent as to the removal executive branch officers.

A review of the Constitutional Convention notes reveals that the Constitution’s silence on removal was intentional.  Those at the Convention deemed it implicit in the Constitution that the President had the exclusive authority to remove executive branch officers.  Further, allowing the President that exclusive authority is consistent with the Constitution’s instruction that the President is responsible that the laws are “faithfully executed.”

Therefore, the 1876 law requiring Senate approval for the removal of Myers was unconstitutional.  Myers’ case was properly dismissed.

Concurring and Dissenting Opinions:

Dissenting Opinion (Holmes):

The Postmaster is a creation of Congress, and Congress should have a say in how postmasters are appointed and removed.

Dissenting Opinion (McReynolds):

Quotes from the Constitutional Convention also support the notion that Senate approval is required before a President may remove an executive branch official.  Further, it would be unworkable to allow the President to remove all executive branch officers on a whim.

Dissenting Opinion (Brandeis):

Marbury v. Madison stands for the proposition that the President does not have the sole power to remove an inferior civil officer.  This case overrules that fundamental decision.

Significance:

Myers v. United States is a fascinating review of the President’s powers under the Constitution and the legislative history of the Constitution itself.

Student Resources:

Read the Full Court Opinion

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