Frank Murphy

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Frank Murphy
BornWilliam Francis Murphy
13 4, 1890
BirthplaceHarbor Beach, Michigan, U.S.
DiedTemplate:Death date and age
Detroit, Michigan, U.S.
NationalityAmerican
OccupationPolitician, lawyer, jurist
Known forAssociate Justice of the Supreme Court of the United States; Governor of Michigan; Mayor of Detroit; Governor-General of the Philippines; U.S. Attorney General
EducationUniversity of Michigan (BA, LLB)
AwardsRanked among ten best mayors in American history (1993 scholars' panel)

William Francis Murphy (April 13, 1890 – July 19, 1949), known as Frank Murphy, was an American politician, lawyer, and jurist whose public career spanned some of the most consequential chapters of twentieth-century American governance. A member of the Democratic Party, Murphy served as Mayor of Detroit during the depths of the Great Depression, as the last Governor-General of the Philippines and the first United States High Commissioner to the Philippines, as the 35th Governor of Michigan, and as the 56th United States Attorney General before President Franklin D. Roosevelt elevated him to the Supreme Court of the United States in 1940. On the Court, Murphy became known for his vigorous defense of civil liberties, authoring the majority opinion in SEC v. W. J. Howey Co. and a notable dissent in Korematsu v. United States, one of the most debated wartime decisions in American constitutional history. Born in Michigan's rural Thumb region and educated at the University of Michigan Law School, Murphy combined a background in progressive Democratic politics with a deep commitment to individual rights that defined his judicial philosophy until his death in 1949 at the age of fifty-nine.[1][2]

Early Life

Frank Murphy was born on April 13, 1890, in Harbor Beach, a small lakeside community in Michigan's Thumb region along the shores of Lake Huron. His birth name was William Francis Murphy, though he was known throughout his life as Frank. He was raised in a devout Irish-Catholic family, and his upbringing in rural Michigan shaped his lifelong identification with working-class and minority communities.[3]

Murphy's family instilled in him a strong sense of public service and social justice. Growing up in a small town at the turn of the twentieth century, he was exposed early to the economic hardships faced by ordinary Americans, experiences that would later inform his political positions on labor rights, racial equality, and civil liberties. Harbor Beach, with its modest population and agricultural economy, provided a stark contrast to the urban settings in which Murphy would eventually make his mark as a public figure.[3]

As a young man, Murphy demonstrated intellectual ambition and a desire to pursue a career in law and public affairs. He attended the University of Michigan, where he earned both a bachelor's degree and a law degree, completing his legal education in 1914. His time at the university exposed him to progressive political thought and legal theory that would become central to his career.[4]

Following the outbreak of World War I, Murphy enlisted in the United States Army and served overseas from 1917 to 1919. His military service, during which he rose through the ranks, provided him with leadership experience and a sense of duty that carried over into his subsequent civilian career. He attained the rank of Lieutenant Colonel and remained associated with the United States Army Reserve even after leaving active service. Murphy would briefly return to military duty in 1942, during World War II, though his primary contributions during that conflict were judicial rather than martial.[2][1]

Education

Murphy attended the University of Michigan, one of the leading public universities in the United States, where he pursued both his undergraduate and legal studies. He received his Bachelor of Arts degree and then enrolled at the University of Michigan Law School, earning his Bachelor of Laws (LLB) degree in 1914.[4] The University of Michigan's law school, which had a strong tradition of progressive legal scholarship, helped shape Murphy's commitment to using the law as an instrument of social justice. After his military service during World War I, Murphy supplemented his legal education with further study, including coursework abroad, which broadened his understanding of international law and governance—knowledge that would prove useful during his subsequent appointment to the Philippines.[4][5]

Career

Early Legal Career and the Sweet Trials

After completing his legal education and military service, Murphy embarked on a career in law and public service in Michigan. He served as a federal attorney and subsequently as a trial judge in Detroit, where he gained prominence for his handling of significant cases during the 1920s.[3]

One of the most notable episodes in Murphy's early judicial career was his role as the presiding judge in the Ossian Sweet trials of 1925–1926. Dr. Ossian Sweet, an African-American physician, and several members of his family and friends were charged with murder after shots were fired from Sweet's newly purchased home in an all-white Detroit neighborhood, killing a member of a mob that had gathered outside the house. The case became a national cause célèbre, drawing the involvement of the NAACP and the celebrated defense attorney Clarence Darrow.[6]

As the trial judge, Murphy delivered a charge to the jury that was noted for its emphasis on equal justice and the rights of homeowners to defend their property regardless of race. In his instructions, Murphy underscored the principle that the law applied equally to all citizens and that a person had a right to defend his home against a threatening mob.[7] The first trial ended in a mistrial; in the subsequent trial of Henry Sweet (Ossian's brother), the jury returned a verdict of not guilty. The Sweet trials marked Murphy as a judge committed to racial justice at a time when such positions were uncommon among white public officials, and the cases significantly enhanced his public reputation.[6][8]

Mayor of Detroit

In 1930, Murphy was elected as the 55th Mayor of Detroit, taking office on September 23, 1930, succeeding Charles Bowles. His tenure as mayor coincided with the most severe years of the Great Depression, and the city of Detroit, heavily dependent on the automobile industry, was among the hardest-hit communities in the nation. Unemployment reached staggering levels, and municipal revenues plummeted.[9]

As mayor, Murphy established an aggressive relief program to address the suffering of Detroit's residents. He organized an unemployment committee and worked to expand direct relief to families in need, earning a national reputation as one of the most active and compassionate municipal leaders during the economic crisis. Murphy's efforts to provide assistance to the city's residents, including significant numbers of African Americans and immigrants who had migrated to Detroit for factory work, were noted for their inclusiveness at a time when many public officials neglected minority communities.[9][3]

Murphy's leadership during this period extended beyond Detroit. In 1932, he became the first president of the United States Conference of Mayors, an organization established to give mayors a collective voice in advocating for federal assistance to cities during the Depression. He served in this capacity from May 1, 1932, until his departure from the mayoralty on May 10, 1933, when he was succeeded by Frank Couzens. His successor as Conference president was James Michael Curley of Boston.[10]

A 1993 panel of 69 scholars ranked Murphy among the ten best mayors in American history, a testament to the impact of his leadership during one of the nation's most challenging periods.[3]

Governor-General and High Commissioner to the Philippines

In 1933, President Franklin D. Roosevelt appointed Murphy as Governor-General of the Philippine Islands, a position he assumed on July 15, 1933, succeeding Theodore Roosevelt Jr.. The Philippines at that time was a territory of the United States, and the Governor-General served as the chief executive authority in the islands. Murphy's appointment reflected Roosevelt's confidence in his administrative abilities and his political alignment with the New Deal.[10][1]

Murphy served as Governor-General until November 15, 1935, when the passage of the Tydings–McDuffie Act and the establishment of the Commonwealth of the Philippines transformed his role. Under the new arrangement, Murphy became the first United States High Commissioner to the Philippines, a position he held from November 15, 1935, to December 31, 1936. As High Commissioner, he served as the representative of the United States government in the Philippines as the islands transitioned toward greater self-governance under President Manuel L. Quezon. Murphy's tenure in the Philippines was marked by his efforts to prepare the territory for eventual independence and to promote economic development and social welfare programs modeled on the New Deal.[10][3]

Governor of Michigan

Murphy returned to Michigan in 1936 and entered the race for governor. He defeated the incumbent Republican governor, Frank Fitzgerald, in the 1936 Michigan gubernatorial election, riding the wave of President Roosevelt's landslide reelection. He was inaugurated as the 35th Governor of Michigan on January 1, 1937, with Leo J. Nowicki serving as his lieutenant governor.[11]

Murphy's single term as governor was dominated by the Flint sit-down strike of 1936–1937, one of the most significant labor actions in American history. Workers at General Motors plants in Flint occupied the factories in a sit-down strike that lasted forty-four days, demanding recognition of the United Automobile Workers (UAW) as their bargaining representative. The strike threatened to become violent, and there was intense pressure on Murphy from business interests and conservative politicians to use the Michigan National Guard to forcibly remove the strikers.[12]

Murphy refused to order the use of force against the strikers. Instead, he deployed the National Guard to maintain order while working to mediate a settlement between General Motors and the UAW. His approach was controversial—praised by labor organizers and many working-class voters but condemned by business leaders and others who viewed the sit-down strikes as illegal trespasses that should have been met with force. Ultimately, General Motors agreed to negotiate with the UAW, a pivotal moment in the history of the American labor movement that helped establish industrial unionism as a major force in the nation's economy.[12][13]

Murphy's handling of the sit-down strike, while celebrated by labor, proved politically costly. In the 1938 gubernatorial election, he lost his bid for reelection to Frank Fitzgerald, the same Republican he had defeated two years earlier. Murphy's single term as governor ended on January 1, 1939.[11][3]

United States Attorney General

After his defeat in the gubernatorial race, Murphy was appointed by President Roosevelt as the 56th United States Attorney General, taking office on January 2, 1939. He succeeded Homer Stille Cummings in the position. As Attorney General, Murphy established the Civil Liberties Unit within the United States Department of Justice, which later became the Civil Rights Section. This was a significant institutional development, as it created for the first time a dedicated federal entity charged with protecting the civil rights of American citizens.[10][1]

Murphy's tenure as Attorney General was relatively brief, lasting just over a year until January 18, 1940, when he was succeeded by Robert H. Jackson. During this time, Murphy also pursued anti-corruption and anti-racketeering cases, continuing the Department of Justice's efforts against organized crime. His establishment of the Civil Liberties Unit is considered one of the most consequential administrative actions of his time as Attorney General.[10]

Supreme Court of the United States

On January 18, 1940, President Roosevelt appointed Murphy to the Supreme Court of the United States as an Associate Justice, filling the vacancy created by the death of Justice Pierce Butler. Murphy's appointment was part of Roosevelt's broader reshaping of the Court following the court-packing controversy of 1937, as the president sought to place justices on the bench who were sympathetic to New Deal legislation and an expansive view of federal power.[14][1]

Murphy served on the Court for nine years, from 1940 until his death on July 19, 1949. During his tenure, he became one of the Court's most consistent advocates for civil liberties and the rights of minorities. He was often aligned with Justices Hugo Black, William O. Douglas, and Wiley Rutledge in what was informally known as the Court's liberal bloc.[10]

Among Murphy's most significant opinions was the majority opinion in SEC v. W. J. Howey Co. (1946), in which the Court established the "Howey test" for determining whether a transaction qualifies as an "investment contract" and is therefore subject to federal securities regulation under the Securities Act of 1933. The Howey test, which examines whether there is an investment of money in a common enterprise with the expectation of profits derived from the efforts of others, has remained a foundational principle of American securities law for decades and continues to be applied in modern cases, including those involving digital assets and cryptocurrencies.[10]

Perhaps Murphy's most historically significant opinion was his dissent in Korematsu v. United States (1944), in which the Court's majority upheld the constitutionality of Executive Order 9066, which authorized the internment of Japanese Americans during World War II. Murphy's dissent was among the most forceful critiques of the majority opinion. He argued that the government's action constituted racial discrimination that fell "into the ugly abyss of racism" and could not be justified by military necessity. Murphy's dissent in Korematsu has gained increasing recognition over the decades as the internment of Japanese Americans has come to be widely acknowledged as a grave injustice. In 2018, Chief Justice John Roberts cited Korematsu as having been wrongly decided, echoing arguments that Murphy had advanced more than seventy years earlier.[10][13]

Murphy also wrote or joined opinions in other notable civil liberties cases during his time on the Court. He was a consistent voice for the protection of freedom of speech, freedom of religion, and the rights of criminal defendants. His judicial philosophy reflected the same progressive commitments that had characterized his political career, and he approached the law with a conviction that the Constitution must serve as a shield for the most vulnerable members of society.[14]

Murphy was succeeded on the Court by Tom C. Clark, who was appointed by President Harry S. Truman.[10]

Personal Life

Frank Murphy never married and had no children. He was known for his devout Roman Catholic faith, which he maintained throughout his life and which influenced his moral outlook on public affairs. His personal life was largely defined by his dedication to public service; colleagues and contemporaries noted that he devoted the vast majority of his time and energy to his professional responsibilities.[15][1]

Murphy maintained close ties to Michigan throughout his life, even during his years of service in the Philippines and Washington, D.C. He died on July 19, 1949, in Detroit, Michigan, at the age of fifty-nine. The cause of death was related to health complications that had affected him during his final years on the bench. He was buried in Rock Falls Cemetery in Harbor Beach, Michigan, returning in death to the small town where he had been born.[3][1]

Recognition

Murphy received significant recognition both during his lifetime and posthumously. His ranking among the ten best mayors in American history by a 1993 panel of 69 scholars reflected the lasting impact of his leadership of Detroit during the Great Depression.[3]

In Detroit, the Frank Murphy Hall of Justice, which houses the 36th District Court, was named in his honor. The building serves as a daily reminder of Murphy's contributions to the city where he served as both judge and mayor. The naming of the hall of justice was fitting given Murphy's lifelong commitment to the legal system and to the principle that the courts should serve as instruments of fairness and equality.[9][13]

Murphy's role in the Ossian Sweet trials has been the subject of continued scholarly and popular interest. The trials have been dramatized and studied as landmark moments in the history of civil rights in America, and Murphy's conduct as presiding judge has been cited as an example of judicial courage during a period of widespread racial prejudice. The University of Detroit Mercy has maintained an archive and educational project related to the Sweet trials, which includes Murphy's charge to the jury.[6][7]

The University of Michigan has also recognized Murphy's contributions, maintaining archival materials related to his career at the Bentley Historical Library.[16]

The State Bar of Michigan has recognized Murphy among its legal milestones, acknowledging his contributions to Michigan law and governance.[11]

Legacy

Frank Murphy's legacy rests on a career that combined progressive political leadership with a judicial philosophy centered on the protection of civil liberties and the rights of minorities. His refusal to use force against the Flint sit-down strikers in 1937, though it cost him reelection as governor, helped establish the principle that government should seek peaceful resolutions to labor disputes and that workers had a right to organize. The success of the UAW in gaining recognition from General Motors, facilitated in part by Murphy's mediation, was a watershed moment in the American labor movement that reshaped the relationship between workers and management in the automobile industry and beyond.[12][13]

On the Supreme Court, Murphy's dissent in Korematsu v. United States has proved to be among the most prescient opinions in the history of the Court. His condemnation of the internment of Japanese Americans as an exercise in racial discrimination anticipated the consensus view that emerged in subsequent decades. The formal repudiation of Korematsu by the Supreme Court in Trump v. Hawaii (2018) vindicated Murphy's position, and his dissent is now studied as a model of principled judicial reasoning in the face of wartime pressure.[10][13]

Murphy's establishment of the Civil Liberties Unit in the Department of Justice during his brief tenure as Attorney General created an institutional framework for the federal protection of civil rights that would become increasingly important during the civil rights movement of the 1950s and 1960s. The unit he created evolved into the Civil Rights Division, which played a central role in enforcing landmark legislation such as the Civil Rights Act of 1964 and the Voting Rights Act of 1965.[10]

His role in the Sweet trials of the 1920s, his leadership in Detroit during the Depression, his service in the Philippines during its transition toward independence, and his defense of individual rights on the Supreme Court form a career that touched upon many of the defining issues of mid-twentieth-century America. Murphy's life and work continue to be studied by legal scholars, historians, and students of American governance.[17][18]

References

  1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 "Frank Murphy".Time.http://www.time.com/time/magazine/article/0,9171,794891,00.html.Retrieved 2026-02-24.
  2. ↑ 2.0 2.1 "The Supreme Court – The Hughes Court (1930–1940)".Supreme Court Historical Society.http://www.supremecourthistory.org/02_history/subs_history/02_c11.html.Retrieved 2026-02-24.
  3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 "Frank Murphy".The Detroit News.http://info.detnews.com/history/story/index.cfm?id=115&category=business.Retrieved 2026-02-24.
  4. ↑ 4.0 4.1 4.2 "Frank Murphy".University of Michigan Law School.http://www.law.umich.edu/newsandinfo/lqn/pasteditions/winter2005/Documents/murphy.pdf.Retrieved 2026-02-24.
  5. ↑ "Frank Murphy".Michigan Bar Journal.http://www.michbar.org/journal/article.cfm?articleID=42&volumeID=6.Retrieved 2026-02-24.
  6. ↑ 6.0 6.1 6.2 "Sweet Trials".University of Detroit Mercy.http://sweettrials.udmercy.edu/index.html.Retrieved 2026-02-24.
  7. ↑ 7.0 7.1 "Judge Murphy's Charge to the Jury".University of Missouri–Kansas City School of Law.http://www.law.umkc.edu/faculty/projects/ftrials/sweet/chargetojury.html.Retrieved 2026-02-24.
  8. ↑ "Sweet Trial Play".University of Detroit Mercy.http://sweettrials.udmercy.edu/sweet_trial_play.htm.Retrieved 2026-02-24.
  9. ↑ 9.0 9.1 9.2 "Frank Murphy – Mayor of Detroit".The Detroit News.http://info.detnews.com/redesign/history/story/historytemplate.cfm?id=115&CFID=10878005&CFTOKEN=54778416.Retrieved 2026-02-24.
  10. ↑ 10.00 10.01 10.02 10.03 10.04 10.05 10.06 10.07 10.08 10.09 10.10 "The Supreme Court – The Stone and Vinson Courts (1941–1953)".Supreme Court Historical Society.http://www.supremecourthistory.org/02_history/subs_history/02_c12.html.Retrieved 2026-02-24.
  11. ↑ 11.0 11.1 11.2 "Michigan Legal Milestones".State Bar of Michigan.http://www.michbar.org/programs/milestones.cfm.Retrieved 2026-02-24.
  12. ↑ 12.0 12.1 12.2 "The Sit-Down Strike".The Detroit News.http://info.detnews.com/redesign/history/story/historytemplate.cfm?id=39&CFID=6667146&CFTOKEN=45521831.Retrieved 2026-02-24.
  13. ↑ 13.0 13.1 13.2 13.3 13.4 "Frank Murphy's Law".Hour Detroit.September 2008.http://www.hourdetroit.com/Hour-Detroit/September-2008/Frank-Murpheys-Law/.Retrieved 2026-02-24.
  14. ↑ 14.0 14.1 "The Supreme Court – The Warren Court (1953–1969)".Supreme Court Historical Society.http://www.supremecourthistory.org/02_history/subs_history/02_c13.html.Retrieved 2026-02-24.
  15. ↑ "Murphy, Frank".GLBTQ Archive.http://www.glbtq.com/social-sciences/murphy_frank.html.Retrieved 2026-02-24.
  16. ↑ "Frank Murphy Papers".University of Michigan Library.http://mirlyn.lib.umich.edu/F/?func=find-b&find_code=WRD&local_base=bent_pub&request=Frank+Murphy.Retrieved 2026-02-24.
  17. ↑ "Review of Frank Murphy biography".H-Net Reviews.http://www.h-net.org/reviews/showrev.cgi?path=26785931291193.Retrieved 2026-02-24.
  18. ↑ "Eastern District of Michigan – Judicial History".United States Court of Appeals for the Sixth Circuit.http://www.ca6.uscourts.gov/lib_hist/Courts/district%20court/MI/EDMI/judges/jac-bio.html.Retrieved 2026-02-24.

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