Springfield Township v. Quick
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63 U.S. 56 (1859)
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U.S. Supreme Court
Springfield Township v. Quick, 63 U.S. 22 How. 56 56 (1859)
Springfield Township v. Quick
63 U.S. (22 How.) 56
Congress reserved the sixteenth section of the public lands in all the new states for the support of schools, for the benefit of the inhabitants of the township.
So that the funds arising from this section are applied to the use of the inhabitants of the township, the state has a right to apply funds raised from other sources, according to its discretion, for the purposes of education throughout the state.
It originated in the County of Franklin, before the Judge of the Fourth Judicial Circuit of the State of Indiana, and was called a civil action. Springfield Township filed a complaint against Quick, the Auditor, and Robeson, the Treasurer, of Franklin County, alleging that they had in their hands a certain sum of money which they were about to distribute erroneously and praying for an injunction to prohibit them from making the distribution in the mode which they proposed.
On the 21st of May, 1855, an injunction was issued by the clerk of the court, according to the prayer of the bill. In August, 1855, the defendants demurred to the bill, upon the ground that the complaint did not state facts sufficient to constitute a cause of action. The court overruled the demurrer, and ordered the defendants to answer; which being declined, the injunction was made perpetual. The defendants appealed to the supreme court, which reversed the judgment, and Springfield Township brought the case up to this Court.
The reservation by Congress of the sixteenth section of the public lands in each township in all the new states, and its appropriation to school purposes for the benefit of the inhabitants of the township, is so well known to all readers of American history, that a brief reference to the legislation of Indiana will be sufficient to explain the point involved in the present case.
Under the authority of an act of Congress, Springfield Township sold the sixteenth section, in 1836, for the sum of $7,423.36; which was invested, and the interest applied to the support of schools within the township. It was conceded, in the argument of this case, that the township was still entitled to the use of this money, and to receive it; but the claim was
for an additional amount, from a fund which accrued under the state laws of Indiana.
In 1851, Indiana adopted a new constitution, the eighth article of which established a school fund, derived from several sources, which were directed to be consolidated into one fund. The first of these sources was the Congressional township fund and the lands belonging thereto. Then followed an enumeration of ten different sources from which revenue was derived, all of which were united into one common fund. This was directed, by an act of the legislature, to be apportioned amongst the several counties of the state, according to the enumeration of scholars therein, without taking into consideration the Congressional township fund in such distribution.
But the constitution also contained the following section, being section seven, in the eighth article, viz.:
"All trust funds held by the state shall remain inviolate, and be faithfully and exclusively applied to the purposes for which the trust was created."
It is evident that, under this act of the legislature, Springfield Township might have received less than the interest of the sum for which section sixteen had been sold, the proceeds of which had been invested. Therefore a suit was brought against the auditor, treasurer, and board of commissioners, of Franklin County, to test the constitutionality of the law; and at November term, 1854, the supreme court of the state decided that the act of the legislature was a violation of the seventh section of the eighth article of the Constitution just quoted, and was consequently null and void. The case is reported in 6 Ind. 84.
In March, 1855, the legislature passed another act, providing for the distribution of the fund, but inserting the following proviso at the end of the one hundred and first section:
"Provided, however, that in no case shall the Congressional township fund &c., be diminished by such distribution, and diverted to any other township."
Springfield Township filed the complaint now in question, alleging that they were entitled to $435.17, being the interest
of the sum for which section sixteen had been sold, and also to $437.76, being its distributive share, making in the aggregate $872.93, to be distributed in said Springfield Township, or, in other words, that the state had no right to charge them, in estimating their distributive share, with what they had received under the Congressional township fund.
The history of this suit has been given in the early part of this statement, by which it will be seen that the Supreme Court of Indiana decided against the claim of Springfield Township. The case is reported in 7 Ind. 636.