American School of Magnetic Healing v. McAnnulty

Background

A school that practices mental healing ran a business based on the idea that the mind can largely control and cure bodily ills. After complaints, the Postmaster General ordered letters addressed to the school withheld. The school sued, and the bill alleges that letters contained checks, drafts, money orders, and money used in its business and that withholding the mail would destroy its business.

Reasoning

The Court explained the central question as whether the Postmaster General could treat the school's claimed cures as mail fraud under the statutes. The Court said the school's claims about the mind's power to heal are a matter of opinion rather than provable fact. It gave examples—electricity, vaccination, homeopathy—to show many medical claims divide opinion and cannot be reliably proven false. Because the admitted facts showed the case was not within the statutes the Postmaster General relied on, his order was a legal mistake and beyond his power. The Court also held that courts can grant relief when an administrative officer acts without statutory authority.

Real world impact

The decision requires that officials not use mail‑fraud statutes to block mail simply because they disagree with a medical theory or belief. The school’s mail must be delivered unless on trial evidence shows actual fraud under the law. The ruling does not decide broader constitutional objections and leaves open the possibility the defendant may still prove on trial that the business, as actually run, violates the statutes.

Dissents or concurrances

Two Justices (White and McKenna) dissented and would have affirmed the lower court, meaning they would have upheld the Postmaster General’s action. They disagreed with the majority’s legal conclusion.