Murray’s Lessee v. Hoboken Land & Improvement Co.
Citation and Court
59 U.S. (18 How.) 272 (1856), Supreme Court of the United States
Facts
The Treasury Department issued a distress warrant to collect funds owed by a government tax collector (Swartwout) who had embezzled public money. The warrant authorized attachment of Swartwout’s property without prior judicial proceedings. Murray’s Lessee, a creditor of Swartwout, challenged the warrant as an unconstitutional deprivation of property without due process and as an improper non-judicial exercise of judicial power.
Issue
Whether Congress may authorize the Treasury to issue distress warrants for the summary collection of debts owed to the United States, without judicial proceedings, consistent with Article III and the Due Process Clause.
Holding
Congress may authorize summary administrative processes — including distress warrants — for collecting debts owed to the government; such matters involving “public rights” need not be adjudicated in Article III courts and do not violate due process.
Rule / Doctrine
The “public rights” doctrine holds that matters historically within the domain of legislative or executive power — such as the collection of debts owed to the government — may be adjudicated outside of Article III courts. Private rights (those at common law or equity) require Article III adjudication, while public rights may be assigned to legislative courts or executive agencies.
Significance
Murray’s Lessee is the foundational case for the public rights doctrine, which remains central to constitutional limits on agency adjudication. It provides the historical basis for allowing Congress to assign public rights disputes (such as tax, benefits, and customs) to administrative agencies and non-Article III tribunals.