Taylor v. Beckham
Taylor v. Beckham, 178 U.S. 548 (1900), was a case heard before the Supreme Court of the United States on April 30 and May 1, 1900, to decide the outcome of the disputed Kentucky gubernatorial election of 1899. The litigants were Republican gubernatorial candidate William S. Taylor and Democratic lieutenant gubernatorial candidate J. C. W. Beckham. In the November 7, 1899, election, Taylor received 193,714 votes to Democrat William Goebel's 191,331. This result was certified by a 2–1 decision of the state's Board of Elections. Goebel challenged the election results on the basis of alleged voting irregularities, and the Democrat-controlled Kentucky General Assembly formed a committee to investigate Goebel's claims. Goebel was shot on January 30, 1900, one day before the General Assembly approved the committee's report declaring enough Taylor votes invalid to swing the election to Goebel. As he lay dying of his wounds, Goebel was sworn into office on January 31, 1900. He died on February 3, 1900, and Beckham ascended to the governorship.

Claiming the General Assembly's decision was invalid, Taylor sued to prevent Beckham from exercising the authority of the governor's office. Beckham countersued Taylor for possession of the state capitol and governor's mansion. The suits were consolidated and heard in Jefferson County circuit court, which claimed it had no authority to interfere with the method of deciding contested elections prescribed by the state constitution, an outcome that favored Beckham. The Kentucky Court of Appeals upheld the circuit court's decision on appeal and rejected Taylor's claim that he had been deprived of property without due process by stating that an elective office was not property and thus not protected by the Fourteenth Amendment.

The injection of Taylor's claim under the Fourteenth Amendment gave him grounds to appeal the decision to the U.S. Supreme Court. In a majority opinion delivered by Chief Justice Melville Fuller, the Supreme Court also rejected Taylor's claim to loss of property without due process and thus refused to intervene on Taylor's behalf, claiming that no federal issues were in question and the court lacked jurisdiction. Justices Gray, White, Shiras, and Peckham concurred with the majority opinion. Justice Joseph McKenna concurred with the decision to dismiss, but expressed reservations about the determination that an elected office was not property. Justice David J. Brewer, joined by Justice Henry B. Brown, contended that the Supreme Court did have jurisdiction, but concurred with the result in favor of Beckham. Kentuckian John Marshall Harlan authored the lone dissent from the majority opinion, claiming that the court did have jurisdiction and should have found in favor of Taylor based on his claim of loss of property without due process. He further argued that elective office fell under the definition of "liberty" as used in the Fourteenth Amendment and was protected by due process.
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Supreme Court of the United States
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Kentucky gubernatorial election of 1899
EVE
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Republican
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gubernatorial
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William S. Taylor
PER
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Democratic
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lieutenant gubernatorial
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J. C. W. Beckham
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William Goebel
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voting irregularities
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David J. Brewer
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Henry B. Brown
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Kentuckian
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John Marshall Harlan
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Taylor v. Beckham
EVE
1900-05-01T00:00:00Z^^http://www.w3.org/2001/XMLSchema#dateTime
May 1, 1900
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