The US Supreme Court’s decision in Barron vs. Baltimore case in 1833 emphasized that the Bill of Rights restricts the rights of the federal government, but not the rights of the states. Barron vs. Baltimore ruling stated that the first ten Amendments to the Constitution of the US that are included in the Bill of Rights could be limited by the states that establish local laws.
Until the adoption of the 14th Amendment (Amendment XIV), regulation of relations property remained in the power of the states in the US. In the XIX century, economic development and the need for federal intervention was inevitable. The essence of the legal controversy was not in the interpretation of property provisions’ withdrawal, but in clarifying the subject of the withdrawal procedure – the states or the Federal Government. The U.S. Supreme Court determined the basis of the exemption doctrine in Barron vs. Baltimore case. The court interpreted proposals on the inadmissibility of withdrawal as a prohibition of withdrawal without payment compensations. Arguments offered by the Supreme Court in Barron vs. Baltimore in 1833 were around a statement that the Bill of Rights does not limit the actions of states’ authorities. Therefore, the main court had no jurisdiction to hear the case and dismissed it. In other words, it was claimed that the state could withdraw property from individuals for public use, but only with fair compensation.
At first glance, the amendments related exclusively to the actions of the Federal government of the US and did not limit the behavior of the states themselves. In 1883, during the trial of Barron vs. Baltimore, presiding judge John Marshall confirmed this understanding. Barron tried to sue the city for the destroyed Wharf, relying on the 5th Amendment, which prohibits the seizure of private property in favor of the state without appropriate compensation. However, judge Marshall had a different opinion on the matter. He ruled that the 5th Amendment was needed solely as a limiter of the US power and was not applicable in states’ domestic law.
However, the Civil War and Reconstruction brought the Fourteenth Amendment to Americans. The 14th Amendment overturned the ruling in Barron vs. Baltimore and proclaimed that no state could take away a person’s life, liberty, and property without due process of law. Barron v. Baltimore case was important as it sowed the seed of revolution in US constitutional law. This revolution began to take shape in 1947 when judge Hugo Black declared the decision in Adamson v. California. After reviewing the Fourteenth Amendment, Black concluded that history showed that the amendment was intended to ensure that no state could deprive its citizens of the benefits and protections of the Bill of Rights.
The court restricted the seizure of property for public purposes for both the states and the Federal government. Barron vs. Baltimore case raised the essential question not on the subject of the seizure of property, but the limits of such seizure. The inclusion of provisions stated in the Bill of Rights in the due process clause of the 14th Amendment nullified the possibility for states to ignore human rights in state law.