Habeas jurisdiction

The Court observed that the rule permitting habeas corpus where a conviction was void for a "clear and manifest want of criminality" was commonly illustrated by Bushel's Case (1670). It recounted that twelve jurors were imprisoned after acquitting William Penn and others of charges arising from an unlawful religious assembly. Although the Court of Common Pleas initially questioned whether it had jurisdiction to issue the writ in a criminal matter, it ultimately discharged the jurors on habeas corpus, concluding that their convictions were void because jurors could not be punished for the verdicts they returned. The Court also described Chief Justice John Vaughan's opinion in Bushel's Case as having "rarely been excelled for judicial eloquence."

The Court concluded that the petitioners' constitutional challenge was properly raised on habeas corpus because personal liberty was sufficiently important to permit review by habeas corpus where the lower court's jurisdiction depended entirely on the validity of the statute.

Merits

On the merits, the petitioners argued that, as state election officials, they could not be subjected to federal arrest and punishment for the performance of their duties. Bradley rejected the petitioners’ argument that state election officials were beyond federal authority. He explained that although states regulated congressional elections, Congress could add federal rules and oversee the conduct of election officials in federal elections.^[3]

Appointments Clause

The Court considered the argument that Congress could not authorize courts to appoint officers whose duties were not judicial in nature, stating that although "it is no doubt usual and proper" to vest the appointment of inferior officers in the branch "to which the duties of such officers appertain," there was "no absolute requirement to this effect in the Constitution," and that the choice of appointing authority "is a matter resting in the discretion of Congress." The Court upheld Congress's decision to authorize federal courts to appoint federal election supervisors to ensure Black participation in elections.^[4]

Addressing its earlier decision in Ex parte Hennen (1839), the Court explained that its observation that officers should ordinarily be appointed by the department to which they most appropriately belonged "was not intended to define the constitutional power of Congress in this regard, but rather to express the law or rule by which it should be governed."^[4]

Continuing its discussion of earlier precedent, the Court distinguished cases in which federal courts had declined to perform duties assigned by Congress, including reviewing pension claims arising from the American Revolutionary War and adjudicating claims for property damage caused by the United States Army during the Patriot War. It concluded that, unlike those statutes, "there is no such incongruity in the duty required as to excuse the courts from its performance, or to render their acts void." The scope of Ex parte Siebold has remained subject to debate because the decision did not clearly define the limits of judicial appointment authority.^[4]