United States v. Morehead

243 U.S. 607, 37 S. Ct. 458, 61 L. Ed. 926, 1917 U.S. LEXIS 1961
CourtSupreme Court of the United States
DecidedApril 30, 1917
Docket685
StatusPublished
Cited by65 cases

This text of 243 U.S. 607 (United States v. Morehead) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Morehead, 243 U.S. 607, 37 S. Ct. 458, 61 L. Ed. 926, 1917 U.S. LEXIS 1961 (1917).

Opinion

Mr. Justice Brandeis

delivered the opinion of the court.

Morehead was indicted under § 37 of the Criminal Code for conspiring with others to commit an offense against the United States. The offense contemplated by the conspirators is subornation of perjury (Criminal Code, § 126) in connection with soldiers’ declaratory statements, to be filed by defendant as agent, covering public lands under the Homestead Law. The perjury set forth in the indictment consists in false swearing before notaries public and clerks of state courts to declaratory statements. The parts of the statement alleged to be false are those which declare:

(1) That the claim is made for his [the applicant’s] exclusive use and benefit, for the purpose of actual settle *609 ment and cultivation, and not either directly or indirectly for the use or benefit of any other person.

(2) That the agent has no right or interest, direct or indirect, in the filing of such declaratory statement.

The District Court sustained a demurrer on the ground that the indictment did not charge a crime, holding that there was no law which required affidavits to soldiers’ declaratory statements; that the Land Department was not authorized to exact them; that consequently no law “authorizes an oath to be administered” to such affidavits; and as perjury is possible only when an oath is authorized to be administered, the procuring of these false oaths could not be subornation of perjury, nor an agreement to secure them a conspiracy to suborn perjury. The case comes here on writ of error under the Criminal Appeals Act (March 2, 1907, c. 2564, 34 Stat. 1246).

The Homestead Law (Rev. Stats., §§ 2304-2309, embodying Act of June 8,1872, c. 338,17 Stat. 333), does not prescribe whether or not an affidavit shall accompany a soldier’s declaratory statement. The affidavit is prescribed by a regulation of the Commissioner of the General Land Office, promulgated with the approval of the Secretary of the Interior. 1 It is clear that a charge of perjury *610 may be based upon a valid regulation of the General Land Office requiring an affidavit if the oath be taken “before a competent tribunal, officer or person.” United States v. Smull, 236 U. S. 405. The question obviously arising here is whether the law authorized the oath to be administered. Another question — ^whether it was administered by a competent tribunal, officer or person — was treated by both parties as requiring decision. Assuming without specially determining the occasion for passing upon the second question, we proceed to consider both.

1. Whether an affidavit may he required to a soldiers’ homestead declaratory statement.

The Homestead Law 1 gives to every soldier who served *611 in the Army of the United States during the War of the Rebellion for ninety days, was honorably discharged and remained loyal to the Government, the right, upon certain conditions, to enter upon 160 acres of the public land as a homestead and receive a patent therefor. To comply with these conditions the applicant must make actual éntry, 1 settlement and improvement; and he must, on applying to enter the land, make and file the affidavit, as provided in Rev. Stats., § 2290, that such application is honestly and in good faith made for the purpose of actual settlement and cultivation, and not for the benefit of any other person. Furthermore, in order to obtain a certificate or patent, he must, under Rev. Stats., § 2291, make proof of his residence for the full period and an affidavit “that no part of such land has been alienated.” The filing of a declaratory statement is not a necessary step in acquiring title to land. It relates to a privilege, akin to pre-emption, by which he may secure, prior to the entry under § 2290, a preferential right to acquire, under the homestead law, the particular tract located on. The privilege is exercised by filing the declaratory statement with the register; and if exercised, lapses unless within six months thereafter, the soldier makes entry and actually commences settlement and improvement. See Charles Hotaling, 3 L. D. 17, 20; Stephens v. Ray, 5 L. D. 133, 134. To render this privilege readily available to soldiers living at a distance, authority is given (Rev. Stats., § 2309) 2 to “enter upon *612 the homestead by filing a declaratory statement,” “as well by an agent as in person.” Thus the soldier can be assured of the selection of an advantageous homestead before perfecting his plan for removing to his new home.

It is a matter of common knowledge that this special privilege, granted to facilitate the acquisition by soldiers of homesteads in grateful recognition of patriotic service, was soon perverted into an instrument of fraud. Soldiers’ declaratory statements, acquired by so-called agents in large numbers, became the subject of extensive speculation. They were used as a means of pre-empting choice lands for a period of six months with a view merely to selling relinquishments of locations to persons .desiring to acquire public lands under the pre-emption or general homestead laws. See 1 L. D. 79. To stay this abuse the General Land Office issued, on December 15, 1882, the circular concerning “Soldiers’ Homestead Declaratory Statements,” (1 L. D. 36) 1 prescribing requirements *613 which have since remained in force and are embodied in substance in the regulation of October 11, 1910.

Defendant contends that this regulation, which has been enforced continuously for nearly thirty-five years,, is invalid. Since the Land Department is expressly charged with the duty of enforcing the public land laws by appropriate regulations 1 and the regulation in question was *614 duly promulgated, the assertion of its invalidity must be predicated either upon its being inconsistent with the statutes or upon its being in itself unreasonable or inappropriate. That the requirement of the soldier’s affidavit to the facts essential to the existence of any right of the applicant under the law is both reasonable and appropriate, can scarcely be doubted. United States v. Smull, 236 U. S. 405, 411; United States v. Bailey, 9 Pet. 238, 255. But defendant urges that the regulation is inconsistent with the statute in that it adds to the requirements of the statute still another condition to be performed before the soldier can acquire his homestead; and hence is legislation, not regulation. But the regulation does hot add a new requirement in exacting the affidavit, as in Williamson

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Bluebook (online)
243 U.S. 607, 37 S. Ct. 458, 61 L. Ed. 926, 1917 U.S. LEXIS 1961, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-morehead-scotus-1917.