Taylor v. Beckham, 178 U.S. 548 (1900), was a case heard before the Supreme Court of the United States on April 30 and May 1, 1900, to decide the outcome of the disputed Kentucky gubernatorial election of 1899.
Claiming the General Assembly's decision was invalid, Taylor sued to prevent Beckham from exercising the authority of the governor's office.
The suits were consolidated and heard in Jefferson County circuit court, which claimed it had no authority to interfere with the method of deciding contested elections prescribed by the state constitution, an outcome that favored Beckham.
The injection of Taylor's claim under the Fourteenth Amendment gave him grounds to appeal the decision to the U.S. Supreme Court.
In a majority opinion delivered by Chief Justice Melville Fuller, the Supreme Court also rejected Taylor's claim to loss of property without due process and thus refused to intervene on Taylor's behalf, claiming that no federal issues were in question and the court lacked jurisdiction.
Justice Joseph McKenna concurred with the decision to dismiss, but expressed reservations about the determination that an elected office was not property.
He further argued that elective office fell under the definition of "liberty" as used in the Fourteenth Amendment and was protected by due process.
[1] The power to decide the outcome of disputed elections remained with the General Assembly under Section 153 of the state constitution.
Brown by a dissident faction of Democrats – the race centered on Goebel and his Republican opponent, Attorney General William S.
[15] When Democratic legislators attempted to convene to approve the committee's report, they found the doors to the state capitol and other public locations in Frankfort blocked by armed citizens.
[16] Leaders from both parties drafted an agreement whereby Taylor and his Lieutenant Governor, John Marshall, would step down from their respective offices, allowing Goebel's lieutenant governor, J. C. W. Beckham, to assume the governorship; in exchange, Taylor and Marshall would receive immunity from prosecution in any actions they may have taken with regard to Goebel's assassination.
The Republican officers, represented by ex-Governor William O'Connell Bradley and future governor Augustus E. Willson among others, argued that the Goebel Election Law deprived citizens of their right to vote.
[18] The case was argued before Judge (and later President) William Howard Taft, who held that the federal court could not prevent the removal of officers by injunction.
[20][21] Republican Attorney General Clifton J. Pratt continued with legal challenges and finally was allowed to serve out his term.
[19] On the same day that Taft's ruling was issued, Taylor filed suit in Jefferson County circuit court against Beckham and Adjutant General John Breckinridge Castleman to prevent them from exercising any authority due the offices they claimed.
[23] Republicans claimed that Taylor's suit, by virtue of having been filed two hours before Beckham's, gave the case precedence in Louisville.
[23] By mutual consent, the parties consolidated the suits, which were heard before Judge Emmet Field in Jefferson County circuit court.
[24] Taylor's attorney's contended that the General Assembly had acted in a quasi-judicial manner, violating the principle of separation of powers.
[30] In addressing the complaints upon which the dismissal of ballots was justified – namely, the intimidation of voters in Jefferson County by the state militia and the use of "thin ballots" in forty Kentucky counties – Bruce maintained that even if the allegations were true, both were the fault of the state, not Taylor and Marshall, and were not sufficient grounds upon which to deny them their right to the offices they claimed.
[31] Maxwell reiterated that the General Assembly had acted within its enumerated powers under the state constitution in deciding the outcome of the disputed election.
[31] Lewis McQuown further argued on behalf of Beckham that, even if Taylor's claim to the governorship were legitimate, the investigation and decision by the General Assembly's contest committee represented sufficient due process.
[33] He further quoted authorities who opined that an elected office was property, using this to contend that Taylor's rights under the Fourteenth Amendment had been violated, thus giving the court jurisdiction.
[33] Finally, Bradley cited irregularities in the proceedings of the contest committee, including insufficient time given for the review of testimony provided in written form by Taylor and Marshall's legal representation.
Brewer issued a dissent stating that he believed that due process had been observed and that the majority opinion should have affirmed the lower court rulings rather than dismissing the case.
[20] Harlan opined that not only did the court have jurisdiction, it should have sustained the writ of error on the grounds that the General Assembly's actions had deprived Taylor and Marshall of property without due process, in violation of the Fourteenth Amendment.
"[28] Whereas the majority opinion wholly ignored the proceedings of the General Assembly as irrelevant (the court lacking jurisdiction) and Brewer and Brown affirmed them, Harlan excoriated the legislature in his dissent.
"Looking into the record before us, I find such action taken by the body claiming to be organized as the lawful legislature of Kentucky as was discreditable in the last degree and unworthy of the free people whom it professed to represent.
"[28] Taylor v. Beckham established as a judicial principle that public offices are mere agencies or trusts, and not property protected by the Fourteenth Amendment.