Thank You For Submiting Feedback!
The Constitution concludes its enumeration of granted powers, with a clause authorizing Congress to make all laws which shall be necessary and proper for carrying into execution the foregoing powers, and all other powers vested by this constitution in the government of the United States, or in any department or officer thereof. The judicial department is invested with jurisdiction in certain specified cases, in all which it has power to render judgment. That a power to make laws for carrying into execution all the judgments which the judicial department has power to pronounce, is expressly conferred by this clause, seems to be one of those plain propositions which reasoning cannot render plainer. The terms of the clause, neither require nor admit of elucidation. The court, therefore, will only say, that no doubt whatever is entertained on the power of Congress over the subject. The only inquiry is, how far has this power been exercised?
A federal court has rendered judgment against plaintiffs, which the Marshal proceeded to serve under the statutes of Kentucky. The plaintiffs filed a motion to quash the Marshal’s return on the execution and the replevin bond taken on the said execution, arguing that Congress had the authority to regulate the proceedings of federal courts. On the other hand, defendants argued that Congress had no power over executions issued on judgments obtained by individuals, and the authority of states on this issue remained unaffected by the U.S. Constitution. Defendants further alleged that Congress should not by law regulate the conduct of its officers in the service of executions on judgments rendered in the federal courts as such power was reserved to the states.
Did Congress have the power to regulate the proceedings of the Federal Courts?
The Court held that the necessary and proper clause of the U.S. Constitution gave Congress, and not the states, the right to delegate to federal courts, the power of altering the modes of proceedings in suits pursuant to the Process Act of September 29, 1789, ch. 21. The Court further held that § 14 of the Judiciary Act of 1789, ch. 20, gave federal courts the power to issue executions on their judgments. Accordingly, the Court entered judgment for the plaintiffs.