Ex parte Bradley

43 S.C.L. 95
CourtCourt of Appeals of South Carolina
DecidedDecember 15, 1855
StatusPublished

This text of 43 S.C.L. 95 (Ex parte Bradley) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Bradley, 43 S.C.L. 95 (S.C. Ct. App. 1855).

Opinion

[97]*97The opinion of the Court was delivered by

Withers, J.

The question here is, whether a prohibition can go to a Magistrate’s Court who have convicted certain slaves of the relators of the offence of harboring certain other slaves hired to one Caraway.

The first ground taken in support of the prohibition is, that the offence was tried in a beat other than that wherein the offence was committed; the position being, that the freeholders can be summoned only from those who live within the bounds of the beat where an offence is perpetrated.

The Court recognizes no legal validity in this position. The magistrate’s jurisdiction is co-extensive with the limits of the judicial district, and there is no statutory restriction fixing the venue of a trial for misdemeanor by a slave to any particular beat, and therefore, neither the jurisdiction of the Court, nor the source whence the .freeholders are to be derived can be thus restricted.

The only other ground upon which this question is to turn? is, the exclusion of the Magistrate’s Court of certain testimony which, it is argued, was competent. • «

The guilt of the negroes upon trial depended upon the testimony of certain slaves who were held upon hire from one of the relators by one Caraway — and the evidence excluded was, that he had once been heard to say (not in reference to this trial), “that no negro under his control should tell any thing against him.”

We are to enquii’e whether the exclusion of such testimony (conceding it to have been competent) is cause for prohibition to restrain the execution of sentence, which 'directs corporal punishment, by chastisement, of ten and fifteen lashes, respectively, upon several slaves convicted.

The process of prohibition arises from the fact, that the supreme authority commits the administration of justice to a variety of tribunals, which creates a necessity that a superintending power shall exist, and be exerted upon fit occasion, to [98]*98restrain each within its prescribed orbit, and so prevent intolerable confusion and disorder. This superintending power cannot be exerted, under our form of government, safely, conveniently, intelligently and promptly, over erratic inferior courts, by any other than the supreme judicial tribunal.

This reflection shows that the original scope of the writ of „ prohibition, so far as it respects inferior judicial tribunals, was limited to the object of confining such to the cognizance of matters lawfully committed to them, by the course of the Common Law or by Statute, and thus of restraining them from excess of jurisdiction. And this conclusion is fortified by what was always said, in early times at any rate, in all suggestions, seeking the writ, to wit., that the cause is drawn ad aliud examen than the proper tribunal, against the dignity of the Crown.

Says Blackstone, 3 Com., 112, “ or .if, in handling matters clearly within their cognizance, they (that is, the Courts Christian,) transgres? the bounds prescribed to them by the laws of England, as where they require two witnesses to prove the payment of a legacy, a release of tithes, or the like, in such cases also, a prohibition will be awarded.” The reason assigned is, that such matters are'not originally within their jurisdiction, but come in collaterally, and ought, therefore, to be decided according to the temporal law, that properly controls them, instead of the law spiritual, that does not; otherwise the same question might be determined in different ways, according to the Court in which it should be depending.

The next succeeding paragraph in the Commentaries shows, that the character of the contest waged in England between the ecclesiastics and the crown, the former denying the supremacy of the civil power over them, gave rise to a free use of the writ of prohibition and other prerogative writs, in order that the “ course of the common law” should be vindicated against the pretensions of the civil law, which was regarded as aiming, under astute and ambitious managers and dignitaries, to work [99]*99hateful and dangerous encroachments upon a venerated system of jurisprudence: one that had been sanctified by the king and barons in Magna Charta. We may thus see, that the idea of enforcing “the course of the common law,” or “the settled principles of the common law,” which phrases, and the like, we sometimes find in our own reports, had, in the mouths of English Judges when applied to the proceedings of inferior Courts alien to that system, as Ecclesiastical Courts, Courts Martial, and so on, an origin and significance, that might render it too strong, if indiscriminately applied to errors of legal interpretation made by inferior tribunals with us, moving however within the orbit prescribed for them, and recognizing the binding obligations of the common law, but from whose decisions an appeal is withheld. It was, accordingly, not inaptly said, in the case of the State vs. Nathan, 4 Rich. 514, that the remedy existing in that case entirely superseded “ the doubtful authority of all those cases wherein the superior Courts have undertaken to correct, by prohibition, the errors or mistakes of inferior Courts, as to what the law is.” Nor was it inaptly said, in the case of the State vs. Wakely, 2 N. & McC. 410, that “ every Court acting clearly within its jurisdiction, in a case legally submitted, is independent of all other Courts to which no appeal is given.” Mere irregularity, insufficiency of proof, or mistaken judgment, afford matter for appeal only. This doctrine is cited with approbation in the case of Price vs. Commissioners of Roads, 3 Hill, 314, though it was also added there, by way of general remark, that the subject matter and the person being within the jurisdiction, the judgment was final and conclusive, unless the Board, in some matter “exceeded the bounds prescribed to them, admitted illegal evidence, or otherwise violated the settled rules of the common law.”

Lord Loughborough, who furnished an authority for the decision of the State vs. Wakely, in the case of Grant vs. Sir Charles Gould, 2 H. Bl. 100, professed in that case, to know only two sources of prohibition, to wit, first where an inferior Court [100]*100assumed to act in matters not within its cognizance, and second, (which he regarded as a species of the other,) “ where an Act has passed in respect to any authority resident in other Courts, as in the Ecclesiastical Courts, in which there is inherent jurisdiction. In such a case, the Courts of Westminster Hall have conceived, that where the authority is limited by an Act of Parliament, the Court which acted differently from the prescription of the Act, was in that instance exceeding its jurisdiction, and, therefore, liable to a prohibition.” Upon such ground ■well rests our ease restraining a Magistrate’s Court from executing sentence of death where a different punishment was applicable, or from trying a second time the same party for the same offence.

Lord Loughborough further remarked upon the ground of receiving improper and rejecting proper evidence, and said;— “ That all Common Law Courts ought to proceed upon the general rule, namely, the best evidence the nature of the case will admit, I perfectly agree. But, that all other Courts are in all cases, to adopt all the distinctions that have been adopted in Courts of common law, is rather a larger proposition than I •choose to assent to.”

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Bluebook (online)
43 S.C.L. 95, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-bradley-scctapp-1855.