United States v. Detroit Timber & Lumber Co.

United States v. Detroit Timber & Lumber Company, 200 U.S. 321 (1906), is a decision of the Supreme Court of the United States. Although the primary issue to the parties of the case was to determine ownership of 44 tracts of timberland, the case has become the standard reference to warn attorneys not to rely on the syllabus of a reported case.

United States v. Detroit Timber and Lumber Company
Argued December 7, 1905
Decided February 19, 1906
Full case nameUnited States, appellant, v. Detroit Timber and Lumber Company, et al.; and Martin-Alexander Lumber Company, et al. appellants, v. United States
Citations200 U.S. 321 (more)
26 S. Ct. 282; 50 L. Ed. 499
Case history
PriorCross-Appeal from the Court of Appeals for the Eighth Circuit
Holding
The headnotes to opinions of the Supreme Court are not the work of the Court but are simply the work of the Reporter of Decisions, giving his understanding of the decision, prepared for the convenience of the legal profession.
Court membership
Chief Justice
Melville Fuller
Associate Justices
John M. Harlan · David J. Brewer
Henry B. Brown · Edward D. White
Rufus W. Peckham · Joseph McKenna
Oliver W. Holmes Jr. · William R. Day
Case opinions
MajorityBrewer, joined by Fuller, Brown, White, Peckham, Holmes, and Day
DissentHarlan, McKenna
Laws applied
Timber Act of June 3, 1878

Prior to Detroit Lumber, the Reporter of Decisions had mischaracterized the holding of Hawley v. Diller[1] in its syllabus for that case. The attorneys representing the United States in Detroit Timber relied on the Hawley syllabus (which incorrectly reported the case) rather than the text of the actual decision (which actually represents the results).[2] The Court pointed out that the headnote is not the work of the Supreme Court and cannot be relied upon to state the Court's decision. Also, for the case cited, the headnote in question had misinterpreted the scope of the decision.[3]

All syllabi issued by the Supreme Court now include a paragraph of boilerplate text to warn readers not to rely on the syllabus for the actual meaning of the decision.[4]

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

See also

References
  1. Hawley v. Diller, 178 U.S. 476 (1900).
  2. Domnarski, William (1996). In the Opinion of the Court. University of Illinois Press. pp. 28–29, 160 n.46. ISBN 978-0-252-06556-9. OCLC 247529812.
  3. Detroit Lumber at 337 ("In the first place, the headnote is not the work of the court, nor does it state its decision, though a different rule, it is true, is prescribed by statute in some states. It is simply the work of the reporter, gives his understanding of the decision, and is prepared for the convenience of the profession in the examination of the reports.... And finally, the headnote is a misinterpretation of the scope of the decision.").
  4. Grantmore, Gil (Winter 2002). "The Headnote". The Green Bag. 5 (2): 157. SSRN 933013.


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