Catron, John (c.1786–1865)

• Author: Stanley I. Kutler
• Pages: 325

Page 325

President ANDREW JACKSON appointed John Catron, his fellow Tennessean and political disciple, to the Supreme Court in 1837. A man who reflected Jackson's own views, Catron had been chief justice of Tennessee. While on the state bench, Catron had undoubtedly endeared himself to Jackson by opposing the BANK OF THE UNITED STATES and challenging JOHN MARSHALL'S Worcester v. Georgia (1832) opinion on Indian rights. Jackson's appointment of Catron filled one of two new positions created by the Judiciary Act of 1837. JOHN MCKINLEY of Alabama received the other appointment. The two decisively altered the geographic complexion of the Court, because five of the nine justices represented slaveholding circuits.

Catron's constitutional law decisions illustrated the judicial search for a balance between national and state power in the antebellum period. For example, in the LICENSE CASES (1847) Catron emphatically held that the commerce power could be exercised by Congress "at pleasure," but that absent such legislation, states might regulate INTERSTATE COMMERCE within their own boundaries. In the PASSENGER CASES (1849) he voted to strike down state taxes on immigrants because Congress had exercised its authority over foreign commerce.

Catron's opinions on the rights and powers of CORPORATIONS varied widely. He concurred in Chief Justice ROGER B. TANEY'S opinion in BANK OF AUGUSTA V. EARLE (1839), holding that states could exclude foreign corporations, and he also agreed when the Court expanded federal court JURISDICTION over corporate activities in Louisville Railroad Co. v. Letson (1844). Except as a party to a diversity suit, however, a corporation, Catron insisted, was not a citizen within the sense of the Constitution. Catron resisted the TANEY COURT'S accommodation with corporate interests in the Ohio bank cases of the 1850s. In PIQUA BRANCH BANK V. KNOOP (1854) he vigorously opposed the use of the CONTRACT CLAUSE to protect state legislative tax exemptions in corporate charters. In a companion case, Catron saw the burgeoning power of corporations as threatening to subvert the state governments that had created them. He believed that the community rights doctrine of CHARLES RIVER BRIDGE V. WARREN BRIDGE COMPANY (1837) had become "illusory and nearly useless, as almost any beneficial privilege, property, or exemption, claimed by corporations" might be construed into a contract to the corporation's advantage. He also...