Taylor and Marshall v. Beckham

1900-05-14

Headline: Federal courts barred from reviewing state legislative election contests, upholding Kentucky’s exclusive control over choosing its governor and limiting federal interference in state election outcomes.

Holding: The Court dismissed the appeal and ruled that federal courts lack authority to review a State’s constitutionally prescribed legislative process for deciding a gubernatorial election, finding no Fourteenth Amendment or republican-form violation warranting federal intervention.

Real World Impact:

Limits federal court review of state legislative election contests.
Affirms state legislatures’ power to finalize disputed state elections.
Makes it harder for losing candidates to get federal relief after state contests.

Topics: election contests, state power over elections, federal court review, due process

Summary

Background

In the 1899 Kentucky governor’s race two main candidates claimed victory. State canvassers certified William S. Taylor as having the most votes and he took the oath of office. William Goebel filed a timely contest. Kentucky law created a Board of Contest made up of legislators drawn by lot to take evidence and report to the General Assembly, which the State’s constitution empowered to finally decide contested elections. The Board reported that Goebel had received the highest number of legal votes, the General Assembly approved that report, and Kentucky courts refused to overturn the Assembly’s action.

Reasoning

The majority, speaking through the Chief Justice, emphasized that States must have exclusive authority to set qualifications for their officers, the procedures for elections, and the ways contests are decided. When a State follows its constitution and laws to resolve such disputes, federal courts should rarely intervene. The majority concluded the Fourteenth Amendment and the national guarantee of a republican form of government did not create a federal question here that justified overturning Kentucky’s legislative determination, so the Supreme Court dismissed the writ of error for lack of jurisdiction.

Real world impact

The ruling confirms that state legislatures and state courts, following state constitutions and statutes, have the final say in many contested state elections. It narrows circumstances in which people or candidates can seek federal court relief after a state’s legislative election decision, leaving many election disputes to state political and judicial processes.

Dissents or concurrances

Two Justices dissented. One argued offices with salaries can be property and so federal review was proper. Another strongly protested that Taylor had a certified right, that the Legislature acted without the evidence, and that the deprivation violated due process and deserved federal review.