In the Invalid Pensions Act of 1792, Congress instructed circuit courts to review claims for pensions by Revolutionary War veterans. Circuit Court determinations would be submitted to the Secretary of War for review, who would then recommend to Congress what individuals would be put on the pension list. In the Circuit Court of the district of Pennsylvania, Justices James Wilson and John Blair and district judge Richard Peters refused to consider William Hayburn’s pension claim. In a letter to President Washington, the jurists explained that the judiciary was a distinct and independent branch of government and that Congress could not assign duties to the courts that were not judicial in nature. Wilson, Blair and Peters also pointed to the fact that decisions under the Act would be reviewed by the legislative and executive branches, which they deemed “radically inconsistent” with judicial independence under the Constitution. In similar letters to Washington, justices and judges sitting in other circuits agreed that the Act was unconstitutional, but reasoned that judges could administer the act in the capacity of commissioners. Attorney General Edmund Randolph petitioned the Supreme Court for a writ of mandamus—an order to the circuit court to consider Hayburn’s pension claim—but the Court delayed ruling on the merits of the case and Congress revised the Pension Act in 1793. The Supreme Court ruled in a 1794 case, U.S. v. Yale Todd, that justices were not authorized to act as commissioners under the 1792 Act.

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