Jurisdictional Conflict between the New York Court of Chancery and the New York Supreme Court of Judicature
In The Founders’ Constitution, an anthology of writings (letters, records of debates and early cases) relating to the Federal Constitution, Chief Justice Kent’s decision in Yates v. Lansing is included as Document 30 of the materials underlying Article 3, Section 1 (The Judiciary).
In Re John V. N. Yates
4 Johns. 315 (New York Supreme Court of Judicature, 1809)
6 Johns. 337 (New York Court for the Correction of Errors, 1810)
This case brought the two great tribunals of New York State — the Supreme Court of Judicature and the Court of Chancery –– into direct conflict. When John V. N. Yates, a distinguished member of the Albany bar but not a solicitor in Chancery, commenced an action in Chancery on behalf of his client Samuel Bacon using the name of a Chancery solicitor, Peter W. Yates, Chancellor John Lansing issued a writ for his arrest. John Yates admitted that he had commenced the action under the name of solicitor Peter W. Yates, but stated that he had done so with that solicitor’s consent. Peter W. Yates denied giving permission, although evidence introduced later in the case indicated that Peter Yates had accepted payment for the consent. John Yates challenged the Chancellor’s power to issue the warrant for his arrest on the ground that the Court of Chancery lacked criminal jurisdiction over the statutory offense he was accused of committing. In response, Chancellor Lansing had Yates jailed for contempt of court.
Yates’ lawyer, Thomas Addis Emmet, immediately applied to Justice Ambrose Spencer, a leading jurist and an associate justice of the Supreme Court of Judicature, for a writ of habeas corpus. After a full hearing, Justice Spencer released the prisoner. As soon as Chancellor Lansing heard that Yates had been discharged, he ordered the sheriff to re-arrest Yates and re-commit him to jail. The sheriff obeyed.
The Albany session of the Supreme Court commenced shortly after the second arrest and Yates’ counsel, Emmet, applied to the full bench for another writ of habeas corpus, stating that “John Lansing, Chancellor of the great Court of Chancery of the State of New York, ordinarily is entitled to, and does command the respect, esteem and admiration of the bar and the people…Therefore, his unwarranted act in this case is to be the more deeply regretted. He has done the unprecedented act of re-committing a man to prison without bail who had been honorably discharged on a writ of habeas corpus issued by a judge of the Supreme Court.”
The main issue before the Supreme Court was whether the Chancellor of the Court of Equity could set aside an order of the Supreme Court releasing a prisoner, and have him re-arrested. Another issue was whether the Court of Chancery, which lacked criminal jurisdiction, had the power to issue the warrant against Yates. Chief Justice James Kent and Associate Justices Smith Thompson and William Van Ness held that the original and second arrests of Yates were lawful. Justices Ambrose Spencer and Joseph C. Yates, (later Governor of New York) dissented.
Thomas Addis Emmet immediately applied for a writ of error to the Clerk in Chancery to bring the case before the Court for the Correction of Errors. The writ was issued in the normal course of business and without the knowledge of the Chancellor. Before the Supreme Court could act on the writ, Chancellor Lansing issued a writ of supersedeas, commanding the judges of the Supreme Court not to make the return to the writ of error. This placed the Supreme Court in a difficult position––it was ordered by one writ of the Court of Chancery to make a return on the writ of error and by another writ issued by the same court, to desist. At Justice Spencer’s suggestion, the Supreme Court made a return to the Court for the Correction of Errors setting out the existence of the two writs and asking the Court for the Correction of Errors for direction. This brought the case before the Court for the Correction of Errors, where the judgment of the Supreme Court, which held that there was good and sufficient law for the commitment of Yates to the custody of the Albany County Sheriff, was reversed and the case was remitted to the Supreme Court for proceedings to effectuate the release of John Yates from custody.
Yates v. Lansing
5 Johns. Rep. 282 (New York Supreme Court of Judicature, 1810)
9 Johns. Rep. 394 (New York Court of the Correction of Errors, 1811)
In a civil action, a judge may not be sued for an error of judgment in any matter within his jurisdiction.
Following the decision of the Court for the Correction of Errors and his subsequent release from custody, Yates brought a civil suit against Chancellor Lansing in the New York Supreme Court based on a section of the Habeas Corpus Act that provided “if any person should knowingly recommit and imprison a person for the same offense,” he should forfeit to the aggrieved party the penalty of $1,200. The case was heard in the Supreme Court of Judicature before Chief Justice Kent and Associate Justices Thompson, Van Ness and Spencer. Thomas Addis Emmet represented Yates and Attorney Harris represented Chancellor Lansing. The Supreme Court held in favor of Lansing, and Chief Judge James Kent wrote an opinion in which he stated:
Whenever we subject the established courts of the land to the degradation of private prosecution, we subdue their independence and destroy their authority. Instead of being venerable before the public, they become contemptible.
In 1811, the case came before the Court for the Correction of Errors with Rodman, Emmet and Martin Van Buren representing Yates, and Attorney Henry and Abraham Van Vechten representing Lansing. The Court for the Correction of Errors affirmed the judgment of the Supreme Court of Judicature, and held that a judge of a court of general jurisdiction cannot be called upon to answer in a civil action for an error of judgment in any matter within his jurisdiction. This case was later cited in support of the principle by the U.S. Supreme Court.