O'Donoghue v. United States
| O'Donoghue v. United States | |
|---|---|
| Argued April 12, 1933 Decided May 29, 1933 | |
| Full case name | Daniel W. O'Donoghue v. The United States; William Hitz v. The United States |
| Citations | 289 U.S. 516 (more) |
| Holding | |
| Courts in the District of Columbia judiciary can be both Article III courts and Article I tribunals at the same time. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Sutherland, joined by McReynolds, Brandeis, Sutherland, Butler, Stone, Roberts |
| Dissent | Hughes, Van Devanter, and Cardozo |
| Laws applied | |
| Compensation Clause | |
O'Donoghue v. United States (consolidated with Hitz v. United States), 289 U.S. 516 (1933), was a United States Supreme Court case in which the court held that courts in the District of Columbia judiciary can be both Article III courts and Article I tribunals at the same time. The two courts at issue in O'Donoghue were a court of general jurisdiction called the Supreme Court of the District of Columbia (now the U.S. District Court for the District of Columbia) and a court of appellate jurisdiction called the Court of Appeals of the District of Columbia (now the U.S. Court of Appeals for the D.C. Circuit).
When O'Donoghue was decided, these courts handled cases arising under either federal or local law. However, an Article III court cannot have jurisdiction over cases that arise under local law. These courts also had extra, non-judicial duties conferred upon them outside of Article III. As such, these courts were widely understood to be legislative courts organized under Article I and not constitutional courts organized under Article III. O'Donoghue allowed these courts to be Article III courts despite that constitutional contradiction by announcing that they were a unique hybrid of Article III court and Article I tribunal.
In 1970, Congress split the duties of these two courts among four adjudicative bodies: two to handle local law and two to handle federal law. The local-law cases are handled by Article I tribunals. The federal-law cases are handled by Article III courts, the same courts that were at issue in O'Donoghue. No hybrid courts like the ones approved of in O'Donoghue currently exist.