West v. Barnes
- Mark Shubert
- Oct 14, 2024
- 3 min read
West v. Barnes
First Supreme Court Decision (1791)
Author: John Jay
Vote Count: 5-0
Majority Justices: James Wilson, William Cushing, John Blair, John Rutledge
West v. Barnes (1791): The first decision made by the United States Supreme Court and the first Supreme Court case which called for oral arguments. Prior to this, the case Van Staphorst v. Maryland was docketed, but that case was settled before the Supreme Court could hear the case. West v. Barnes was argued in front of the Court on August 2, 1791 and it was decided upon on August 3, 1791.
William West was a revolutionary war militia general, farmer, a judge from Scituate, Rhode Island, and an anti-federalist leader. Due to a failed molasses deal to the Jenckes family from Providence in 1763, he owed a mortgage on his farm. William West made payments for twenty years on the mortgage, and then asked the state for permission to set up and run a lottery in 1785 in order to help pay off the rest. Because of West’s services during the Revolution, the state of Rhode Island granted him the permission to do so. Many of the proceeds were not paid in gold or silver, but instead were paid in paper currency. William West tendered the payment in the paper currency which was allowed according to the statute by since he was lodging the money with a state judge, which would be collected within 10 days.
David Leonard Barnes, a well-known attorney and an heir of the Jenckes family, eventually brought forward a lawsuit in a federal court based on the diversity jurisdiction which asserted that silver or gold payment was needed, rather than the paper currency. Despite the lack of formal legal training, William West represented himself pro se in June 1791 in the circuit court before Chief Justice John Jay and two other justices. All of them rejected his arguments. West then tried to appeal the case to the Supreme Court on a writ of error, in an attempt to comply with all of the statutory directions. William West was not able to travel to Philadelphia to represent himself in the suit, so he hired Pennsylvania’s attorney general, William Bradford, Jr., to represent him.
On the appeal, David Barnes examined the procedural irregularities of the case. He asserted that the writ had been only signed and sealed circuit court clerk in Rhode Island rather than the Supreme Court clerk, which he said was necessary. William West lost the case due to this procedural issue and eventually was forced to surrender his farm. The Supreme Court held that a writ of error needed to be issued within ten days by the Supreme Court Clerk as required by the Federal statute, rather than a lower court’s clerk. As a result, Congress ultimately modified this procedure with the section nine of the Judicial Act of 1792, which allowed circuit courts to issue writs, helping citizens who lived far away from the capitol.
This Supreme Court case was one of the earliest potential ones that could have allowed judicial review in the United States. In this case, the Supreme Court had the chance to overturn a statute enacted by Rhode Island State which discussed fulfilling a contract through lodging the payment a debt by using paper currency. However, the Supreme Court did not exercise any judicial review in respect to the legislature.
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