United States v. Germaine

1878 United States Supreme Court case

United States v. Germaine
Supreme Court of the United States
Decided October 1, 1878
Full case name	United States v. Germaine
Citations	99 U.S. 508 (more)
Holding
While an inferior officer may be appointed a Department Head, only a principal officer may be a Department Head.
Court membership
Chief Justice Morrison Waite Associate Justices Nathan Clifford · Noah H. Swayne Samuel F. Miller · Stephen J. Field William Strong · Joseph P. Bradley Ward Hunt · John M. Harlan
Case opinion
Majority	Miller, joined by unanimous
Laws applied
U.S. Const. art. II, § 2, cl. 2

United States v. Germaine, 99 U.S. 508 (1878), was a decision of the United States Supreme Court concerning the Appointments Clause.

References

Text of United States v. Germaine, 99 U.S. 508 (1878) is available from: Cornell Justia

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United States v. Germaine

United States Appointments Clause case law

Appointment of Officers

Officers vs. Employees	United States v. Hartwell (1867) United States v. Mouat (1888) United States v. Smith (1888) Auffmordt v. Hedden (1890) Burnap v. United States (1920)
Inferior Officers	United States v. Germaine (1878) Ex parte Siebold (1879) Freytag v. Commissioner (1991) Edmond v. United States (1997) Lucia v. SEC (2018) United States v. Arthrex, Inc. (2021)
Recess Appointments	NLRB v. Noel Canning (2014)
Challenges to Appointments	Ryder v. United States (1995) Carr v. Saul (2021)
Appointments by Congress	Shoemaker v. United States (1893) Springer v. Government of the Philippine Islands (1928) Buckley v. Valeo (1976) MWAA v. CAAN (1991) Weiss v. United States (1994)

Removal of Officers

Limits on Removal Power	United States v. Perkins (1886) Parsons v. United States (1897) Myers v. United States (1926) Humphrey's Executor v. United States (1936) Wiener v. United States (1958) Morrison v. Olson (1988) Free Enterprise Fund v. PCAOB (2010) Selia Law v. CFPB (2020) Collins v. Yellen (2021)
Removal by Congress	Bowsher v. Synar (1986)

Jurisdiction stripping
Thunder Basin Coal Co. v. Reich (1994) Free Enterprise Fund v. PCAOB (2010) Elgin v. Department of Treasury (2012) Axon Enterprise, Inc. v. Federal Trade Commission (2023)