BLATCHFORD, SAMUEL

BLATCHFORD, SAMUEL

Samuel Blatchford was an astute and conscientious jurist who served on the U.S. Supreme Court from 1882 to 1893.He was known primarily for his maritime and patent expertise and for his remarkable productivity. During his eleven-year tenure on the High Court he wrote 430 opinions and two dissents. His most noteworthy opinions, Chicago, Milwaukee & St. Paul Railway Co. v. Minnesota, 134 U.S. 418, 10 S. Ct. 462, 33 L. Ed. 970 (1890), and Budd v. People of New York, 143 U.S. 517, 12 S. Ct. 468, 36 L. Ed. 247 (1892), were roundly criticized for their apparently contradictory conclusions about DUE PROCESS under the FOURTEENTH AMENDMENT of the U.S. Constitution.

Blatchford was born in New York City on March 9, 1820, the son of Richard Blatchford, a lawyer, and Julia Ann Mumford. He attended Columbia College (renamed Columbia University), and graduated with honors at age seventeen in 1837. Blatchford served as a trustee of Columbia from 1867 to 1893.

After graduation Blatchford became the private
secretary of Governor William H. Seward of
New York, a family friend. Blatchford studied
law, was admitted to the New York bar in 1842,
and practiced for three years with his father in
Manhattan. Blatchford then joined Seward’s law
firm in Auburn, New York. He married Caroline
Appleton in 1844.

In 1854 Blatchford started his own law firm
and he eventually became a respected authority
on international, maritime, and patent law.
Because of his extensive knowledge of patent law
he was asked by lawmakers to help write key federal
statutes governing patent infringement.
Blatchford made a significant contribution
to the legal profession by organizing a reporting
system for federal case law. During much of the
nineteenth century federal opinions were not
compiled or readily accessible to practicing
lawyers. In 1852 Blatchford collected and published
federal court ADMIRALTY decisions in
Blatchford’s Circuit Court Reports, a series that
grew to twenty-four volumes. He also produced
Blatchford’s and Howland’s Reports, a volume of
admiralty cases from the District Court for the
Southern District of New York, and Blatchford’s
Prize Cases, a collection of cases from circuit and
district courts. His case reporting is credited
with improving legal research.
Although Blatchford turned down an
opportunity to sit on the New York Supreme
Court in 1855, he eventually accepted another
court appointment and rose through the ranks
of the judiciary. In 1867 he was appointed by
President ANDREW JOHNSON as district judge of
the Southern District of New York. Nine years
later President RUTHERFORD B. HAYES named
him circuit judge for the second judicial circuit.
Blatchford reached the pinnacle of his career
in 1882, when President CHESTER A.ARTHUR nominated
him to the U.S. Supreme Court. Blatchford
was Arthur’s third choice for the seat
vacated by WARD HUNT. Although the U.S. Senate
had already confirmed New York politician
ROSCOE CONKLING,Arthur’s first choice, Conkling
declined to serve. Arthur’s second choice, Senator
George F. Edmunds, of Vermont, also turned
down the honor. Known as a hardworking and capable lawyer and judge, Blatchford accepted
the nomination and was easily confirmed.
In 1890, Blatchford wrote Chicago, Milwaukee,
an opinion that shielded business from public
regulation. The Court ruled that the
reasonableness of railroad rates could not be
decided by an independent commission established
by the Minnesota Legislature. The state
law establishing the commission was ruled
unconstitutional because it did not allow for
court review and therefore violated the railway’s
right to due process. Two years later, in Budd,
Blatchford changed course and the Court held
that the state legislature could determine business
rates affecting the public interest. The
inconsistency between the two cases produced
widespread criticism.

Blatchford wrote one significant civil liberties
opinion, Counselman v. Hitchcock, 142 U.S.
547, 12 S. Ct. 195, 35 L. Ed. 1110 (1892), a case
that strengthened the constitutional right
against SELF-INCRIMINATION. Blatchford held
that under the FIFTH AMENDMENT of the U.S.
Constitution, a witness could not be ordered to
testify unless the state promised never to use the
information against her or him.
Blatchford died in 1893 in Newport, Rhode
Island, at age seventy-three.

FURTHER READINGS
Congressional Quarterly. 1989. Guide to the U.S. Supreme
Court. 2d ed.Washington,D.C.: Congressional Quarterly.
Leon, Friedman, and Fred L. Israel, eds. 1969. The Justices of
the United States Supreme Court, 1789–1969: Their Lives
and Major Opinions. New York: Chelsea House.