Miller, Samuel Freeman
Also found in: Encyclopedia.
Miller, Samuel Freeman
Samuel Freeman Miller served as an associate justice of the U.S. Supreme Court from 1862 to 1890. During his long tenure on the Court, Miller played a major role in restricting the reach of the Fourteenth Amendment into areas of the law reserved to the states. He is most famous for writing the majority opinion in the Slaughter-House Cases, 83 U.S. (16 Wall.) 36, 21 L. Ed. 394 (1873).
Miller was born on April 5, 1816, in Richmond, Kentucky, and grew up on a farm. He attended Transylvania University, where he earned a medical degree in 1838. Miller practiced medicine for ten years, and during that time he taught himself law. In 1847, he was admitted to the Kentucky bar, and soon afterward he abandoned his medical practice for a law practice in Knox County, Kentucky.
Miller became more interested in politics after he became an attorney. A member of the Whig Party, Miller was opposed to Slavery, a position that caused him difficulty in Kentucky as pro-slavery sentiment began to rise. In 1850, he moved to Iowa, which was more tolerant of his antislavery views. He established a law practice in Keokuk, Iowa, and became a prominent member of the Republican Party and a supporter of Abraham Lincoln's presidential campaign in 1860.
Lincoln appointed Miller to the U.S. Supreme Court in 1862, during the most difficult period for the Union during the Civil War. Miller voted to sustain Lincoln's suspension of Habeas Corpus and to try civilians by military courts-martial. Following the war, Miller voted to uphold the constitutionality of loyalty oaths that were required of former Confederates who wished to hold public office.
Miller is best known for his majority opinion in the Slaughter-House Cases in 1873. At issue was the scope of the authority in the Fourteenth Amendment, which had been passed in 1868 to guarantee that states could not restrict the constitutional rights of citizens and businesses. The case involved a Louisiana state law that allowed one meat company the exclusive right to slaughter livestock in New Orleans. Other packing companies were required to pay a fee for using the slaughterhouses. Those companies filed suit, claiming that the law violated the privileges and immunities clause of the Fourteenth Amendment, which stated that "no state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States."
Miller upheld the Louisiana Monopoly law, ruling that the Privileges and Immunities Clause had a limited effect because it only reached privileges and immunities guaranteed by U.S. citizenship, not state citizenship. The law in question concerned state rights; therefore, the Fourteenth Amendment had no effect. In Miller's view, the Fourteenth Amendment was designed to grant former slaves legal equality, and not to grant expanded rights to the general population. In addition, Miller was concerned that a broad interpretation of the Fourteenth Amendment would give too much power to the federal government and that it could distort the concept of Federalism, which grants the states a large measure of power and autonomy.
Having set the standard for interpreting the Fourteenth Amendment, Miller and most members of the Court followed it during the 1870s and 1880s. Miller and the Court struck down state-sponsored racial discrimination under the amendment but refused to do the same to private discrimination, most notably in the Civil Rights Cases, 109 U.S. 3, 3 S. Ct. 18, 27 L. Ed. 835 (1883). In these cases, the Court held that federal laws that banned private discrimination in public transportation and public accommodation were unconstitutional because the Fourteenth Amendment only reaches state-enacted discrimination.
In a nonjudicial role, Miller served on the electoral commission that counted the electoral votes in the deadlocked and disputed presidential election of 1876 between rutherford b. hayes and samuel j. tilden. During the 1880s, some Republican leaders promoted Miller as a presidential candidate, but nothing came of it.
"It does not … follow, that when a word was used in a statute … seventy years since, that it must be held to include everything to which the same word is applied at the present day."
Miller died on October 13, 1890, in Washington, D.C.
Fairman, Charles. 2002. Mr. Justice Miller and the Supreme Court, 1862-1890. Union, N.J.: Lawbook Exchange.
Hall, Kermit L., ed. 1992. The Oxford Companion to the Supreme Court of the United States. New York: Oxford Univ. Press.Ross, Michael A. 2003. Justice of Shattered Dreams: Samuel Freeman Miller and the Supreme Court During the Civil War Era. Baton Rouge: Louisiana State Univ. Press.