Springer v. Government of the Philippine Islands

Springer v. Government of the Philippine Islands, 277 U.S. 189 (1928), was a decision of the United States Supreme Court concerning the Appointments Clause.

Background
The case was an action of quo warranto, on behalf of the Government against Milton E. Springer, Dalamacio Costas, and Anselmo Hilario, the three directors of the National Coal Committee. The Philippine Legislature created a coal company and a bank, and the majority of the stock was owned by the government itself. The company was created through Act No. 2705, and the Governor-General was required to subscribe fifty-one percent of the capital of the corporation. The power to vote on the stock arguably lay in a committee or a Board of control. The board was composed of the Governor-general, the Speaker of the House of Representatives, and the President of the Senate. Defendants argued that section 4 of Act No. 2705, which was amended by section 2 of Act No. 2822 was invalid. Section 2 of Act No. 2822 stated that voting on behalf of the Philippine Islands was exclusively vested in the committee. The Philippine Legislature passed statute Act No. 2705, which defined the duties of the board of control.

Opinion of the Court
Section 4 of Act No. 2705, amended by Section 2 of Act No. 2822 was held to be invalid. The Philippine Legislature unlawfully determined who of its members sit on the committee, while still legally providing a National Coal Company. Appointments to positions lie in the Executive powers, not the Legislative.