Martin Thomas Manton

Martin Thomas Manton was a United States circuit judge who served on the United States Court of Appeals for the Second Circuit from 1918 to 1939. Appointed by President Woodrow Wilson, a Democrat, Manton rose to become the senior circuit judge of one of the nation's most influential federal appellate courts during the 1930s. His judicial career ended in resignation and criminal conviction when he was found guilty of conspiracy to obstruct justice in connection with accepting improper payments from parties with cases before his court. He remains one of the most prominent examples of judicial corruption in American federal court history.

Early life and legal career

Born on August 2, 1880, in New York City, Manton pursued legal education at Columbia Law School, where he earned his Bachelor of Laws degree in 1901. Following his graduation, he immediately entered private practice in New York City, where he would work for fifteen years until his appointment to the federal bench in 1916. During a portion of his time in private practice, Manton formed a partnership with William Bourke Cockran, establishing himself within New York's legal community.

Manton's private practice brought him involvement in several notable matters. In 1915, he served as attorney for Charles Becker, a New York City police officer who became the central figure in the Rosenthal murder trial. Becker was ultimately convicted and executed in this high-profile case, which drew significant public attention in New York during that period. This representation demonstrated Manton's willingness to take on prominent criminal defense work and his standing among New York attorneys during the years before his judicial appointment.

His legal career in New York City during the early twentieth century positioned him for consideration for federal judicial office. After fifteen years of practice, Manton's professional trajectory shifted dramatically when President Woodrow Wilson nominated him to the federal district court in 1916, beginning a judicial career that would span more than two decades and ultimately end in infamy.

Federal appellate service

President Wilson nominated Manton to the United States District Court for the Southern District of New York on August 15, 1916, to fill a vacancy created by Judge Charles Merrill Hough. The Senate confirmed the nomination on August 23, 1916, and Manton received his commission the same day. His tenure as a district judge proved brief, lasting less than two years, as he was elevated to the circuit court in 1918.

On March 12, 1918, President Wilson nominated Manton to the United States Court of Appeals for the Second Circuit to occupy a seat vacated by Judge Alfred Conkling Coxe Sr. The Senate confirmed this appointment on March 18, 1918, and Manton received his commission that same day. This appointment placed him on one of the most prestigious federal appellate courts in the nation, with jurisdiction over New York, Connecticut, and Vermont. The Second Circuit has long been regarded as among the most influential courts below the Supreme Court, particularly in matters of commercial law and federal jurisdiction.

During his service on the Second Circuit, Manton achieved significant seniority and institutional responsibility. From 1926 to 1938, he served as a member of the Conference of Senior Circuit Judges, the predecessor body to what is now known as the Judicial Conference of the United States. This conference serves as the principal policy-making body for the administration of the federal court system. By the 1930s, Manton's seniority elevated him to the position of Senior Circuit Judge of the Second Circuit, a role roughly equivalent to the modern Chief Judge position, giving him administrative responsibilities and influence over the court's operations.

In 1922, Manton came under consideration for appointment to the Supreme Court of the United States. President Warren G. Harding contemplated nominating Manton to succeed Justice William R. Day in what was then understood as the "Catholic seat" on the Court, an informal tradition of maintaining religious diversity among the justices. However, Manton encountered significant opposition during this consideration process, led by Chief Justice William Howard Taft. Ultimately, President Harding selected Pierce Butler for the appointment instead, and Manton remained on the Second Circuit.

During his tenure on the appellate court, Manton participated in several cases that attracted public attention. He wrote a dissenting opinion in obscenity litigation concerning the novel Ulysses by James Joyce, decided as United States v. One Book Entitled Ulysses in 1934. In that case, Judges Learned Hand and Augustus Noble Hand concluded that the book was not obscene under applicable legal standards, but Manton dissented, voting to uphold the ban on the work. The case became a landmark in American obscenity law and literary freedom. Manton also participated in a series of decisions involving the control and financing of companies operating the New York City Subway system, matters of considerable public importance during that era.

Manton's judicial service came to an abrupt end in 1939. He suffered severe financial losses during the Great Depression, and subsequently began accepting gifts and loans from individuals and entities with matters pending before his court. Some of these payments allegedly constituted outright bribes in exchange for favorable rulings in patent litigation and other cases. As rumors of corruption circulated, investigations commenced. Manhattan District Attorney Thomas E. Dewey applied pressure through his investigation and wrote to the Chairman of the House Judiciary Committee recommending impeachment proceedings based on findings from a federal grand jury. Facing this scrutiny, Manton resigned from the bench on February 7, 1939, ending his federal judicial service.

Following his resignation, Manton was indicted in the United States District Court for the Southern District of New York, the same court where he had once served as a judge. John T. Cahill, the United States Attorney for the Southern District of New York, represented the government at trial. Judge William Calvin Chesnut of the District of Maryland presided over the jury trial. In his defense, Manton called prominent character witnesses, including former Democratic presidential candidates Alfred Smith and John W. Davis. Despite this defense, the jury acquitted Manton of bribery charges but convicted him of conspiracy to obstruct justice.

The conviction was appealed to the Second Circuit, where Manton had served for over two decades. Given the obvious conflict of interest, a specially constituted panel heard the appeal, consisting of retired Supreme Court Justice George Sutherland, sitting Supreme Court Justice Harlan Fiske Stone, and newly appointed Second Circuit Judge Charles Edward Clark. This distinguished panel affirmed Manton's conviction. He was sentenced to two years in Lewisburg Federal Penitentiary and ultimately served seventeen months (though one source indicates nineteen months) before his release.

Jurisprudence and legacy

Manton's judicial legacy is inextricably linked to his criminal conviction and the scandal that ended his career. His case stands as one of the most significant instances of federal judicial corruption in American history, involving a judge who had risen to senior status on a major appellate court. The revelation that a senior circuit judge had been selling decisions undermined public confidence in the judiciary and highlighted vulnerabilities in the system of judicial ethics and oversight.

The Manton scandal attracted extensive press coverage and public attention. S. Burton Heath of the New York World-Telegram received the 1940 Pulitzer Prize for reporting in recognition of his coverage of the Manton trial, reflecting the significance contemporaries attached to the case. The conviction of such a high-ranking federal judge was unprecedented in its scope and impact on the legal profession.

After his release from prison, Manton relocated to Fayetteville, New York, where he lived in relative obscurity. He died there on November 17, 1946, at the age of sixty-six, seven years after his resignation from the bench and several years after completing his prison sentence.

The Manton case has been examined in subsequent legal and historical scholarship as a cautionary example of judicial misconduct. Multiple books have analyzed his career and downfall, including Joseph Borkin's work on corrupt judges and studies of judicial appointments and courtroom proceedings. His participation in the Ulysses obscenity case, where he voted to ban the novel, remains a footnote in literary and First Amendment history, though his dissent was overshadowed by the majority opinion that allowed the book's publication and his later disgrace.