Samuel Blatchford

Samuel Blatchford
Blatchford circa 1893
Samuel Blatchford
Born	9 3, 1820
Birthplace	Auburn, New York, U.S.
Died	Template:Death date and age Newport, Rhode Island, U.S.
Nationality	American
Occupation	Jurist, attorney
Known for	Associate Justice of the Supreme Court of the United States
Education	Columbia College (BA)
Spouse(s)	Caroline Appleton (m. 1844)

Samuel Milford Blatchford (March 9, 1820 – July 7, 1893) was an American attorney and jurist who served as an Associate Justice of the Supreme Court of the United States from April 3, 1882, until his death on July 7, 1893. Born into a prominent New York family with deep connections to law and politics, Blatchford built a distinguished career as an expert in admiralty and patent law before ascending to the federal bench. He served as a judge of the United States District Court for the Southern District of New York from 1867 to 1878 and as a judge of the United States Circuit Court for the Second Circuit from 1878 to 1882 before his elevation to the nation's highest court. Nominated by President Chester A. Arthur, Blatchford was confirmed by the United States Senate and succeeded Justice Ward Hunt. During his eleven years on the Supreme Court, Blatchford authored numerous opinions, many of which addressed questions of patent law, international law, and the constitutional limits of state regulatory power. He remained on the bench until his death in Newport, Rhode Island, and was succeeded by Justice Edward Douglass White.

Early Life

Samuel Milford Blatchford was born on March 9, 1820, in Auburn, New York, a small but growing city in the Finger Lakes region of the state. His family occupied a position of considerable social and political standing. His father, Richard Milford Blatchford, was a prominent New York attorney and political figure who later served as the United States Minister to the Papal States during the administration of President Abraham Lincoln. Richard Blatchford was closely associated with William H. Seward, the future Secretary of State, who also hailed from Auburn, New York. This connection to Seward and the broader network of New York Whig and later Republican politics shaped the environment in which the younger Blatchford came of age.

Growing up in a household steeped in legal and political discourse, Samuel Blatchford was exposed from an early age to the workings of the American legal system. His father's law practice in New York City and his relationships with leading political figures of the era provided the young Blatchford with both intellectual stimulation and practical connections that would serve him throughout his career. The family's prominence in New York legal circles meant that Samuel had access to mentors and educational opportunities that prepared him for a career in the law.

Auburn, New York, during Blatchford's youth was a community closely tied to the political movements of the antebellum period. The town's association with figures such as Seward, who became one of the most prominent anti-slavery politicians in the country, placed the Blatchford family at the center of some of the most consequential political debates of the era.

Education

Samuel Blatchford demonstrated academic aptitude from an early age. He attended Columbia College in New York City, where he proved to be an exceptional student. Blatchford graduated from Columbia at the top of his class in 1837, at the age of only seventeen. His early graduation reflected both his intellectual abilities and the accelerated educational timelines common among elite students in the antebellum period.

Following his graduation from Columbia, Blatchford pursued the study of law. In the mid-nineteenth century, aspiring lawyers in the United States commonly prepared for the bar not through formal law school attendance but through apprenticeship in the offices of established attorneys. Blatchford followed this path, reading law under the guidance of prominent practitioners. His family connections facilitated his legal training, and he was admitted to the New York bar in 1842, beginning what would become one of the most consequential legal careers of the nineteenth century.

Career

Early Legal Practice

After his admission to the bar in 1842, Blatchford entered private legal practice in New York. He served as secretary to Governor William H. Seward of New York, a position that deepened his understanding of government and politics while reinforcing the personal connections that had been cultivated through his father's association with Seward. This early experience in the orbit of one of the most influential political figures in New York gave Blatchford a thorough understanding of the intersection of law and governance.

Blatchford established himself in private practice in New York City, where he developed a specialization in admiralty law and patent law—two fields that were becoming increasingly important as the American economy expanded through maritime commerce and industrial innovation. His expertise in these areas distinguished him among New York attorneys and laid the foundation for his later judicial career. Blatchford became known as a meticulous legal scholar, and he compiled and published reports of federal court decisions, producing volumes that became important reference works for practitioners. His compilations of circuit court opinions, known as Blatchford's Circuit Court Reports, were widely used and demonstrated his commitment to making federal case law accessible and organized.

Blatchford's private practice spanned more than two decades, during which he handled complex commercial litigation and built a reputation as one of the foremost admiralty and patent lawyers in the United States. His deep familiarity with federal court procedure and substantive law made him a natural candidate for appointment to the federal bench.

United States District Court

On May 3, 1867, Blatchford received his first judicial appointment when President Andrew Johnson nominated him to serve as a judge of the United States District Court for the Southern District of New York. He succeeded Judge Samuel Betts, who had served on that court for decades. The Southern District of New York was—and remains—one of the busiest and most important federal trial courts in the United States, handling a large volume of admiralty, commercial, and patent cases owing to New York City's status as the nation's commercial and shipping center.

Blatchford's expertise in admiralty and patent law proved particularly suited to the docket of the Southern District. During his eleven years on the district court bench, from 1867 to 1878, he adjudicated a substantial number of cases in these specialized fields. His opinions were noted for their thoroughness, careful reasoning, and attention to technical detail. The volume and quality of his judicial output during this period enhanced his reputation as one of the most capable federal judges in the country.

Blatchford's tenure on the district court coincided with a period of rapid industrial growth and increasing commercial complexity in the United States. The post-Civil War era saw an expansion of patent litigation as inventors and manufacturers sought to protect their innovations, and admiralty law grew more complex as international maritime commerce expanded. Blatchford's court was at the center of many of these developments, and his decisions helped shape the emerging body of federal law governing patents and maritime disputes.

He was succeeded on the Southern District bench by Judge William G. Choate when he was elevated to the circuit court.

United States Circuit Court

On March 4, 1878, Blatchford was nominated by President Rutherford B. Hayes to serve as a judge of the United States Circuit Court for the Second Circuit, one of the most prestigious appellate courts in the federal judiciary. He succeeded Judge Alexander S. Johnson on the Second Circuit bench. The Second Circuit, encompassing New York and the surrounding states, handled appeals from the very district court on which Blatchford had previously served, and its docket was heavily weighted toward the commercial, patent, and admiralty cases in which Blatchford had developed particular expertise.

During his four years on the circuit court, from 1878 to 1882, Blatchford continued to produce well-regarded opinions and further solidified his standing as one of the nation's leading jurists in patent and commercial law. His appellate opinions demonstrated a careful analytical approach and a commitment to consistency in federal law. The quality of his work on the Second Circuit brought him to the attention of national political leaders as a potential candidate for the Supreme Court.

Blatchford was succeeded on the Second Circuit by Judge William J. Wallace when he was elevated to the Supreme Court in 1882.

Supreme Court Nomination and Confirmation

In 1882, the retirement and subsequent death of Associate Justice Ward Hunt—who, like Blatchford, was a New Yorker—created a vacancy on the Supreme Court of the United States. President Chester A. Arthur, himself a New Yorker, sought to fill the seat with a qualified jurist from the same state, in keeping with the informal tradition of maintaining geographic balance on the Court.

Arthur's path to nominating Blatchford was not straightforward. The President first offered the nomination to Roscoe Conkling, the powerful former United States Senator from New York and Arthur's political mentor. Conkling was confirmed by the Senate but declined the appointment, one of the few instances in American history of a confirmed nominee refusing to take a seat on the Supreme Court. Arthur then nominated Senator George F. Edmunds of Vermont, who also declined. Blatchford was Arthur's third choice for the vacancy.

President Arthur nominated Blatchford on March 13, 1882. The Senate confirmed the nomination on March 22, 1882, by voice vote and without significant opposition. Blatchford took the judicial oath of office on April 3, 1882, becoming the forty-ninth Associate Justice of the Supreme Court of the United States. His confirmation proceeded smoothly, reflecting the broad respect he had earned through his long service on the federal bench and his reputation as a noncontroversial, technically skilled jurist.

Supreme Court Tenure

Blatchford served on the Supreme Court for eleven years, from April 3, 1882, until his death on July 7, 1893. During his tenure, he authored a significant number of opinions for the Court, many of which dealt with the patent, admiralty, and commercial law questions that had defined his earlier judicial career.

One of the most notable cases in which Blatchford participated was Chicago, Milwaukee and St. Paul Railway Co. v. Minnesota (1890), in which the Supreme Court addressed the limits of state regulatory power over railroad rates. In his opinion for the Court, Blatchford held that a Minnesota statute establishing a commission to set railroad rates without providing for judicial review of the commission's determinations violated the Due Process Clause of the Fourteenth Amendment. The decision was significant in establishing the principle that state regulation of business must be subject to judicial review to ensure that it does not deprive companies of property without due process of law. This case contributed to the development of the doctrine of substantive due process and had lasting implications for the relationship between government regulation and private enterprise in the United States.

Blatchford also wrote the majority opinion in Counselman v. Hitchcock (1892), a case addressing the scope of the Fifth Amendment privilege against self-incrimination in the context of congressional investigations. The Court held that a federal statute purporting to grant immunity from prosecution was insufficient to compel testimony if it did not provide full transactional immunity. The decision established important principles regarding the scope of compelled testimony and the protections required by the Fifth Amendment.

Another significant case during Blatchford's tenure was Blatchford v. Native Village of Noatak, which, while decided after Blatchford's death, bore his name and addressed questions of sovereign immunity—an area in which his earlier rulings contributed to the development of legal doctrine. During his years on the bench, Blatchford also decided numerous patent cases, reflecting his long expertise in the field. His patent opinions were characterized by careful technical analysis and a systematic approach to the complex factual questions that patent litigation presented.

Blatchford's judicial philosophy was generally conservative and closely tied to the text of statutes and the Constitution. He was not known as a judicial innovator or a proponent of sweeping doctrinal change, but rather as a careful, methodical jurist whose opinions were valued for their precision and clarity. His approach reflected the dominant judicial philosophy of the late nineteenth century, which emphasized the protection of property rights and the limitation of governmental power over economic activity.

During the last year of his life, Blatchford's health began to decline. Reports from the period indicate that he was in failing health in the spring and summer of 1893.

Personal Life

Samuel Blatchford married Caroline Appleton in 1844. The couple remained married until Blatchford's death in 1893. Little detailed information about their private family life has been documented in public sources, consistent with the conventions of the era regarding the privacy of judicial figures.

Blatchford was known among his contemporaries for his industrious work habits and his scholarly disposition. His commitment to compiling and publishing federal court reports during his years in private practice reflected a personality oriented toward systematic organization and intellectual rigor. Colleagues and contemporaries described him as diligent and thorough, qualities that were evident in his judicial opinions throughout his career on the bench.

Blatchford's health deteriorated in the final months of his life. By the summer of 1893, he was reported to be seriously ill. He died on July 7, 1893, in Newport, Rhode Island, where he had gone in an effort to recuperate. His death created a vacancy on the Supreme Court that was eventually filled by Edward Douglass White of Louisiana, who was nominated by President Grover Cleveland.

Blatchford was buried in Green-Wood Cemetery in Brooklyn, New York.

Recognition

Blatchford's contributions to American jurisprudence were recognized primarily through the esteem in which his judicial opinions were held by the legal community during and after his lifetime. His compilations of federal court reports, published during his years in private practice, were considered valuable reference works and contributed to the systematization of federal case law in the nineteenth century.

His opinion in Chicago, Milwaukee and St. Paul Railway Co. v. Minnesota is frequently cited in legal scholarship as an important development in the doctrine of substantive due process and the relationship between state regulatory power and constitutional protections for property rights. Similarly, his opinion in Counselman v. Hitchcock remains a foundational case in Fifth Amendment jurisprudence regarding the scope of immunity required to compel testimony.

Blatchford's estate was the subject of legal proceedings following his death, which were reported in the press.

The Federal Judicial Center maintains a biographical entry for Blatchford as part of its records of all federal judges in American history. His life and career are also documented in several reference works on the Supreme Court, including The Oxford Companion to the Supreme Court of the United States and various biographical dictionaries of Supreme Court justices.

Legacy

Samuel Blatchford's legacy rests primarily on his long and productive service on the federal bench and his contributions to the development of American patent law, admiralty law, and constitutional doctrine. Over the course of more than a quarter century as a federal judge—first on the district court, then on the circuit court, and finally on the Supreme Court—Blatchford adjudicated thousands of cases and helped establish legal principles that guided American commerce and governance during a period of rapid economic transformation.

His work in patent law was particularly significant. During the latter half of the nineteenth century, the United States experienced an unprecedented surge in technological innovation, and the federal courts were called upon to adjudicate an increasing number of disputes over patent rights. Blatchford's expertise in this area, developed over decades of practice and judicial service, positioned him as one of the most authoritative voices on patent law in the federal judiciary. His opinions in patent cases helped clarify the standards for patent validity, infringement, and remedies at a time when the law in this field was still developing.

Blatchford's role in shaping the doctrine of substantive due process through his opinion in Chicago, Milwaukee and St. Paul Railway Co. v. Minnesota had consequences that extended well beyond his own lifetime. The principle that state regulation of business is subject to judicial review to ensure compliance with due process requirements became a central tenet of constitutional law in the late nineteenth and early twentieth centuries, influencing the Supreme Court's approach to economic regulation for decades.

Although Blatchford is not among the most frequently discussed Supreme Court justices in popular historical accounts, legal historians recognize his contributions to the technical and doctrinal development of federal law. His career illustrates the importance of specialized legal expertise in the federal judiciary and the role that lower court service can play in preparing judges for the demands of the Supreme Court.