Justice Stephen Johnson Field

Justice Stephen Johnson Field joined the U.S. Supreme Court on May 20, 1863, filling a new seat that had been created by Congress that year under the Tenth Circuit Act. Field was born on November 4, 1816 in south-central Connecticut but grew up in Massachusetts. He graduated from Williams College in 1837 and then studied law before being admitted to the New York bar in 1841.

Field then left for California during the Gold Rush of the late 1840s. He spent a brief period in the California legislature in the early 1850s and later joined the California Supreme Court in 1857. After two years as an Associate Justice, he served as the Chief Justice of the California Supreme Court from 1859 to 1863.

President Abraham Lincoln nominated Field to the U.S. Supreme Court on March 6, 1863. The Senate confirmed him on March 10, and he took the judicial oath about two months later. Field would stay on the Court for longer than any Justice before him, surpassing the record set by Chief Justice John Marshall. His tenure remains the second-longest in Supreme Court history after Justice William Douglas.

Field wrote perhaps his most famous opinion in Pennoyer v. Neff, describing the doctrine of personal jurisdiction. This defines when a court holds authority over the parties to a lawsuit. In a notable dissent in the Slaughterhouse Cases, meanwhile, Field argued that the majority took too narrow a view of the Privileges or Immunities Clause of the Fourteenth Amendment.

Field sometimes sought to curb federal power, joining a majority of the Court in striking down an income tax law and ruling that the Sherman Antitrust Act did not apply to manufacturing. However, his opinion in Chae Chan Ping v. U.S. helped lay the foundation for the plenary power doctrine in immigration law, which mandates judicial deference to the political branches.

Field retired from the Supreme Court on December 1, 1897 and was replaced by Justice Joseph McKenna. On April 9, 1899, Field died in Washington, D.C.

Selected Opinions by Justice Field:

Pennoyer v. Neff (1878)

Topic: Lawsuits & Legal Procedures

Proceedings to determine the personal rights and obligations of parties over whom the court has no jurisdiction do not constitute due process.

Chae Chan Ping v. U.S. (1889)

Topic: Immigration & National Security

The power of Congress to exclude foreign nationals from the U.S. is an incident of sovereignty that cannot be surrendered by the treaty-making power.

Pace v. Alabama (1883)

Topic: Equal Protection

A state law prohibiting a white person and an African-American person from living with each other “in adultery or fornication” did not violate the Constitution even though it prescribed penalties more severe than those to which the parties would be subject, were they of the same race and color.