United States v. Wurzbach

United States v. Wurzbach, 280 U.S. 396 (1930), is a unanimous ruling by the US Supreme Court that the term "political purpose," as used in the Federal Corrupt Practices Act, was not impermissibly vague.[1] The Supreme Court reversed the district court, which had quashed an indictment under the Act.

United States v. Wurzbach
Argued January 20, 1930
Decided February 24, 1930
Full case nameUnited States v. Harry M. Wurzbach
Citations280 U.S. 396 (more)
50 S.Ct. 167; 74 L. Ed. 508; 1930 U.S. LEXIS 758
Case history
Prior31 F.2d 774 (W.D. Tex. 1929)
Holding
The sixth section of the act of August 15, 1876, is not unconstitutional
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Oliver W. Holmes Jr. · Willis Van Devanter
James C. McReynolds · Louis Brandeis
George Sutherland · Pierce Butler
Edward T. Sanford · Harlan F. Stone
Case opinion
MajorityHolmes, joined by unanimous

Background

Harry M. Wurzbach, a member of the US House of Representatives from Texas, was indicted under the Federal Corrupt Practices Act for receiving money from employees of the US government. The District Court of the United States for the Western District of Texas had thrown out the indictment on two grounds:

  • The term "political purpose" did not include the behavior in question.
  • If the term includes such behavior, the Act was unconstitutional.

Decision

Associate Justice Oliver Wendell Holmes, Jr. delivered the unanimous opinion of the Court, which contains just 752 words.

Holmes dismissed almost out of hand the district court's lengthy discussion of the terms and structure of the Act: "This language is perfectly intelligible and clearly embraces the acts charged."[2] The district court had concluded that Article 1, Section 4 of the Constitution permits Congress to regulate only the time, place, and manner of elections, and primary elections do not fall under federal control (as per Newberry v. United States).[3][2] Holmes, however, argued that the ability to restrict receipt of funds was not contingent upon when or where the funds were received (primary or general election).[4] Holmes cited Ex parte Curtis.[5][6]

The district court was reversed and the case remanded.

References
  1. United States v. Wurzbach, 280 U.S. 396 (1930).  This article incorporates public domain material from this U.S government document.
  2. Wurzbach, 280 U.S. at 398.
  3. Newberry v. United States, 256 U.S. 232 (1921).
  4. Wurzbach, 280 U.S. at 398-399.
  5. Ex parte Curtis, 106 U.S. 371 (1882).
  6. Wurzbach, 280 U.S. at 399.
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