Ex parte Siebold

Ex parte Siebold, 100 U.S. 371 (1879), was a United States Supreme Court case concerning the separation of powers and the Appointments Clause.

Ex parte Siebold
Supreme Court of the United States
Decided October 1, 1879
Full case name	Ex parte Siebold
Citations	100 U.S. 371 (more)
Holding
So long as the vesting is consistent with the separation of powers, Congress has discretion to vest the appointment of an inferior officer in the President, a Department Head, or a Court of Law.
Court membership
Chief Justice Morrison Waite Associate Justices Nathan Clifford · Noah H. Swayne Samuel F. Miller · Stephen J. Field William Strong · Joseph P. Bradley Ward Hunt · John M. Harlan
Case opinions
Majority	Bradley, joined by Waite, Swayne, Miller, Strong, Hunt, and Harlan
Dissent	Field, joined by Clifford
Laws applied
U.S. Const. art. II, § 2, cl. 2

Background

Baltimore election officials were indicted under the Enforcement Act of 1870 for stuffing ballot boxes and destroying the votes of African Americans in a congressional election. In defense, they contested Congress' authority under the Appointments Clause to control their work as state officials.^[1]

Decision

Writing for the majority, Associate Justice Joseph P. Bradley rejected the officials' claim to independence from federal oversight of their federal elections. Opining that the Fifteenth Amendment to the United States Constitution authorized the Enforcement Act of 1870, he upheld the act.^[1]

Legacy

The Harvard Law Review has deemed this case as an exception to the anti-commandeering doctrine expressed in Printz v. United States (1997), reasoning that it allows the federal government to control state officials and their resources in pursuance of its Elections Clause authority.^[2]