Patterson v. Lamb

Background

A man who had been ordered to report for immediate military service on November 11, 1918, went to his local draft board in Davenport, Iowa, and was placed with other draftees who were to board a train for Camp Dodge. On Armistice Day he and many others were told the draft call was canceled, told to return home, and later received a certificate dated November 14, 1918, labeled “Discharge from Draft” with a small final pay check. Believing this matched an honorable Army discharge, he later sought tax exemptions and an honorable-discharge certificate, was denied, and sued federal officials to obtain an honorable discharge instead of the draft discharge.

Reasoning

The Court addressed whether the War Department could issue a “Discharge from Draft” in the special circumstances created by the Armistice. It explained that existing Army rules and later War Department circulars provided for a separate draft discharge form (Form No. 638, Circular No. 651 and Circular No. 111) to cover draftees who were not finally integrated into the Army. Because the Armistice created an unprecedented situation, the War Department acted within its authority to select an appropriate certificate. The Court rejected the argument that this man should be placed in a better status than tens of thousands of other draftees who were nearer final acceptance. It therefore reversed the Court of Appeals and upheld the Department’s action.

Real world impact

The ruling leaves in place the War Department’s long-standing paperwork classifications for World War I draftees and limits efforts by those who received draft discharges to convert them into honorable discharges. The Court did not decide other procedural questions such as delay or broader limits on reviewing War Department decisions.