Coleman v. Miller
307 U.S. 433 · Supreme Court of the United States · 1939
Facts
In June 1924, Congress proposed the Child Labor Amendment. In January 1925, the Kansas Legislature adopted a resolution rejecting the proposed amendment. In January 1937, a resolution to ratify the amendment was introduced in the Kansas Senate, resulting in a 20-20 tie vote. The Lieutenant Governor, as presiding officer, cast a deciding vote in favor of the resolution, which was subsequently adopted by the House of Representatives. Twenty-one senators who voted against the resolution and three members of the House then brought a mandamus action in the Kansas Supreme Court. They sought to prevent the certification of the ratification, challenging the Lieutenant Governor's vote and arguing the amendment had lost its vitality due to prior rejection and the lapse of nearly thirteen years since its proposal.
Procedural history
Twenty-one Kansas senators and three representatives initiated an original proceeding in mandamus in the Supreme Court of Kansas. The Kansas Supreme Court entertained the action, ruled that the Lieutenant Governor was authorized to cast the deciding vote, and that the proposed amendment retained its vitality, denying the writ of mandamus. The U.S. Supreme Court granted certiorari to review this decision.
Issue
Did the proposed Child Labor Amendment lose its vitality and become unratifiable due to the Kansas Legislature's prior rejection and the significant lapse of time since its submission by Congress?
Holding
The Supreme Court affirmed the Kansas Supreme Court's denial of mandamus, holding that the questions of the efficacy of a prior rejection and the reasonableness of the time for ratification are political questions for Congress, not the judiciary. Therefore, state officials should not be restrained from certifying the ratification.
Rule
The efficacy of a state legislature's ratification of a constitutional amendment, despite a previous rejection or attempted withdrawal, is a political question for the political departments, with ultimate authority in Congress. Similarly, when Congress proposes an amendment without fixing a time limit for ratification, the question of whether it has lost its vitality due to the lapse of time is a political question for Congress to decide, not the courts. Judicial determination of a "reasonable time" is inappropriate as it lacks satisfactory criteria and involves appraising complex political, social, and economic conditions.
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