UNITED STATES – Appellant
Versus
MUNOZ-FLORES, (1990) – Respondent
United States Supreme Court
UNITED STATES v. MUNOZ-FLORES, (1990)
No. 88-1932
Argued: February 20, 1990 Decided: May 21, 1990
After respondent pleaded guilty to two federal misdemeanors, a Federal Magistrate, inter alia, ordered him to pay, as required by 18 U.S.C. 3013, a monetary "special assessment" to the Crime Victims Fund established by the Victims of Crime Act of 1984. He moved to correct his sentence, asserting that the assessments were unconstitutional because Congress had passed 3013 in violation of the Origination Clause, which mandates that "all Bills for raising Revenue shall originate in the House of Representatives." The Magistrate denied the motion, and the District Court affirmed. However, the Court of Appeals reversed, holding that, while respondents claim did not raise a nonjusticiable political question, 3013 was a bill for raising revenue that had originated in the Senate and, thus, was passed in violation of the Clause.
Held:
1. This case does not present a nonjusticiable political question. It has none of the characteristics that Baker v. Carr, 369 U.S. 186, 217, identified as essential to a finding that a case raises such a question. Pp. 389-397.
(a) Invalidating a law on Origination Clause grounds would not evince a "lack of . . . respect," within the meaning of Baker, for the House. If disrespect, as the Government uses that term, were sufficient to create a political question, every judicial resolution of a constitutional challenge to a congressional enactment would be impermissible. Congress often explicitly considers whether bills violate constitutional provisions, and any laws enactment is predicated at least implicitly on a judgment that the law is constitutional. These factors do not foreclose subsequent judicial scrutiny of a laws constitutionality. To the contrary, this Court has a duty to conduct such a review. Pp. 389-391.
(b) The Governments two attempts to distinguish an Origination Clause claim from other constitutional challenges are rejected. First, its argument that the House has the power to protect its institutional interests by refusing to pass a bill if it believes that the Clause has been violated does not absolve this Court of its responsibility to consider constitutional challenges to congressional enactments. Even if the Housed had a greater incentive to safeguard its origination prerogative than it does to refuse to pass a bill that it believes is unconstitutional for other [495 U.S. 385, 386] purposes, the fact that one governmental institution has mechanisms available to guard against incursions into its power by other such institutions does not require that the Judiciary remove itself from the controversy by labeling the issue a political question. Second, the Governments suggestion that judicial intervention is unwarranted because this case does not involve individual rights is simply irrelevant to the political question doctrine, which is designed to restrain the Judiciary from inappropriate interference in the business of the other branches. The litigants identity is immaterial to the presence of these concerns in a particular case. More fundamentally, the Governments claim is in error. This Court has repeatedly adjudicated separation-of-powers claims brought by people acting in their individual capacities, and provisions for the separation of powers within the Legislative Branch are not different in kind from the provisions concerning relations among the branches: Both sets of provisions safeguard liberty. Pp. 392-395.
(c) Also rejected is the Governments argument that another Baker factor justifies a finding that the case is nonjusticiable: The Court could not fashion "judicially manageable standards" for determining either whether a bill is "for raising Revenue" or where a bill "originates." The Government suggests no reason why a judicial system capable of determining, e. g., when punishment is "cruel and unusual" and when bail is "[e]xcessive" w
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