Although an ardent patriot, a signer of the Declaration of Independence, and an associate justice of the U. S. Supreme Court who made a significant contribution to nineteenth-century American jurisprudence, Samuel Chase is best known for his interpretation of the Sedition Act of 1798 and his impeachment trial in 1804. Chase was born on April 17, 1744. His mother, Matilda Walker, died at his birth and he was raised by his father, Thomas Chase, an Episcopalian minister renowned for his tenacity, impulsiveness, and tendency to live beyond his means, which led to his imprisonment in 1746 for unpaid debts. The elder Chase passed on these characteristics to his son but also provided him with a sound classical education.
At eighteen, Chase began studying law in the offices of John Hammond and John Hall in Annapolis. Admitted to the bar in 1761, he was appointed prosecutor in the mayor’s court, a position that provided him with a meager salary but permitted him to represent clients in civil suits for debt. In May 1762, he married Ann (Nancy) Baldwin of Anne Arundel County. The couple had seven children, three of whom died in infancy. In 1763, Chase commenced legal practice in Frederick County, Maryland, and became politically active, aligning himself with the country party against the elite-controlled court party. In the following year, he obtained a seat in the assembly. During the Stamp Act crisis, Chase mobilized the ‘‘middling sort,’’ participated in the drafting of Maryland’s resolutions to the Stamp Act Congress, and helped to organize the Sons of Liberty in Annapolis.
In the early 1770s, Chase assumed a leading role in the movement to lower clerical salaries and tobacco inspection fees, which he regarded as oppressive. He became a member of the nonimportation committee of Annapolis in 1770 and a vigorous supporter of colonial resistance after Britain’s imposition of the Intolerable Acts. Selected as a delegate to the First and Second Continental Congresses, Chase embraced the principle of ‘‘no taxation without representation,’’ assailed British suppression of colonial trade, and denounced the royal navy’s seizure of American ships. He emerged as one of Maryland’s leading advocates of Independence, but distanced himself from the colony’s radical faction led by John Hall, Matthias Hammond, and Charles Ridgely, whose policies he believed threatened the colony’s internal stability and social order. Chase joined Charles Carroll and Benjamin Franklin on the commission sent to Canada to request support for resistance to the imperial authorities.
In the late 1770s, Chase advocated that large states cede their western lands to the union. He also supported the confiscation of British property and the expansion of paper money. His views reflected his speculative interests and difficulty in repaying debts. In 1778, he was accused of having breached public trust by using for speculative purposes confidential information on wheat and flour shortages provided to Congress. Although absolved of these charges, he became the central figure in the infamous flour scandal and was defeated in the 1778 elections for Congress. The scandal plagued him throughout his public life.
Fearing the domination of national affairs by elites, identifying state legislatures as bastions of popular liberties, and regarding the participants in the Constitutional Convention as having exceeded their mandate to amend the Articles of Confederation, Chase initially supported the Antifederalist cause. The adoption of the Bill of Rights, his affinity for English traditions and fear of the radicalism of the French Revolution, and his heightened concern about social unrest after the Whiskey Rebellion and the Fell’s Point Riot led to his Federalist conversion. Presiding over the Court of Oyer and Terminer in Baltimore, Chase sought to distinguish between the freedom and licentiousness of the press in 1794.
Appointed to the Supreme Court in 1796, Chase quickly distinguished himself and contributed to the development of American jurisprudence. In the British debt case, Ware v. Hylton (1796), he ruled on the supremacy of national treaties over state law. In Hylton v. United States (1796), he recognized the power of the Supreme Court to void congressional legislation deemed to be unconstitutional and declared the federal excise tax on carriages to be a duty. In United States v. Worrall (1798), Chase refused arguments to prosecute a crime on the basis of common law, noting that federal courts could not ‘‘punish a man for any act, before it is declared by law of the United States to be criminal.’’ In Calder v. Bull (1798), he laid foundations for the doctrine of ‘‘substantive due process’’ by acknowledging the importance of fundamental principles not specifically set out in the Constitution.
Chase’s interpretation of the Sedition Act of 1798 precipitated strong Republican criticism and culminated in the call for his impeachment in 1804. Alleging irregularities in his handling of John Fries’s trial for treason and James Callender’s prosecution for seditious libel, as well as judicial indiscretion before a grand jury in Newcastle, Delaware, in 1803 when he denounced President Jefferson’s repeal of the Judiciary Act of 1801, John Randolph tabled seven articles of impeachment in the House of Representatives. Although none received the Senate’s two-thirds majority required for Chase’s removal from the Court, the impeachment trial enshrined him as a symbol of Federalist political partisanship. Samuel Chase died in Baltimore on June 19, 1811.
GORDON S. BARKER
References and Further Reading