United States v. Detroit Timber & Lumber Co.
United States v. Detroit Timber and Lumber Company | |
---|---|
Argued December 7, 1905 Decided February 19, 1906 | |
Full case name | United States, appellant, v. Detroit Timber and Lumber Company, et al.; and Martin-Alexander Lumber Company, et al. appellants, v. United States |
Citations | 200 U.S. 321 (more) 26 S.Ct. 282, 50 L.Ed. 499, |
Case history | |
Prior | Cross-Appeal from the Court of Appeals for the Eighth Circuit |
Holding | |
The headnotes to opinions of the Supreme Court are not the work of the Court, but are simply the work of the Reporter of Decision, giving his understanding of the decision, prepared for the convenience of the legal profession | |
Court membership | |
| |
Case opinions | |
Majority | Brewer, joined by Fuller, Brown, White, Peckham, Holmes, and Day |
Dissent | Harlan, McKenna |
Laws applied | |
Timber Act of June 3, 1878 |
United States v. Detroit Timber & Lumber Company, 200 U.S. 321 (1906), is a decision of the Supreme Court of the United States. Although the primary issue to the parties of the case was to determine ownership of 44 tracts of timberland, the case has become the standard reference to warn attorneys not to rely on the syllabus of a reported case.
Prior to Detroit Lumber, the Reporter of Decisions had mischaracterized the holding of Hawley v. Diller[1] in its syllabus for that case. The attorneys representing the United States in Detroit Timber relied on the Hawley syllabus rather than the text of the actual decision.[2] The Court pointed out that the headnote is not the work of the Supreme Court, and cannot be relied upon to state the Court's decision, and that, for the case cited, the headnote in question had misinterpreted the scope of the decision.[3]
All syllabuses issued by the Supreme Court now include a paragraph of boilerplate text that references this case, warning readers not to rely on the syllabus for the actual meaning of the decision.[4]
See also
References
- ^ Hawley v. Diller, 178 U.S. 476 (1900).
- ^ Domnarski, William (1996). In the Opinion of the Court. University of Illinois Press. pp. 28–29, 160 n.46. ISBN 9780252065569. OCLC 247529812.
- ^ Detroit Lumber at 337 ("In the first place, the headnote is not the work of the court, nor does it state its decision, though a different rule, it is true, is prescribed by statute in some states. It is simply the work of the reporter, gives his understanding of the decision, and is prepared for the convenience of the profession in the examination of the reports.... And finally, the headnote is a misinterpretation of the scope of the decision.").
- ^ Grantmore, Gil (Winter 2002). "The Headnote". The Green Bag. 5 (2): 157.