United States v. Wurzbach
Can federal employees be prohibited by law from soliciting donations for political purposes, and is the statute on the books too vague? In 1930, the case United States v. Wurzbach decided these issues. The court's holding in United States v. Wurzbach has had an impact on corruption charges ever since. Today, we'll take a look at how this case was decided and what the Supreme Court's decision means for elected representatives and other members of the federal government.
The Case Begins
During the 1928 Congressional elections, Republican incumbent Harry M. Wurzbach seemed like a sure bet. Even when Republicans lost Texas in the 1920 and 1924 elections, Wurzbach won by handy margins. However, in 1928, the Republican, Herbert Hoover, won the national election and Texas's electoral vote—but Wurzbach was not re-elected.
Wurzbach alleged election fraud and successfully appealed his case to the House of Representatives. His opponent, McCloskey, had already been a member of Congress for 11 months when he found his title stripped away and he was replaced by Wurzbach, who served until his death.
However, Wurzbach's problems weren't over once he was re-seated in the United States Congress. He had already been accused of having obtained funds from Congress members and other federal employees to help his primary campaign. Wurzbach appealed his case to the Supreme Court, because he felt that the law was unconstitutionally vague in what it considered a “political purpose” and who the act applied to. He also alleged that its constitutionality was compromised because the law didn't specify a punishment. United States v. Wurzbach decided on these questions in 1930, just after Wurzbach was re-seated in Congress.
The Court's Ruling: No Vagueness for Wurzbach
Wurzbach said that the law was vague about who it applied to, and was therefore unconstitutional. The court ruled that this may be so, but that even if it was, members of the House of Representatives, like Wurzbach, were specifically mentioned by title in the statute. This means that even if some other federal employee may have been able to sue due to this vagueness, a sitting Congressman certainly could not.
The Court's Ruling: Law is Constitutional
Wurzbach's second contention was that the corruption law he had been charged under never specifically indicated what a “political purpose” was for the purposes of the statute. Wurzbach maintained that because Republican primary elections were not governed by Congress, but rather by the Republican National Committee, Congress had no power to enforce a law about whether or not people were allowed to solicit donations from federal employees for these elections.
The Supreme Court quashed this line of argument in United States v. Wurzbach, deciding that Congress should always have the ability to police its own members and ensure that corruption did not occur during any events leading up to the federal election.
The Court's Ruling: Uncertain Punishment
The court held that the law's lack of a specified punishment could be appealed at the time when a punishment was actually issued. Since Wurzbach had not yet been told what his punishment would be, he had no standing to sue on this basis.