Oliver P. Field


Any study of the ex post facto clauses of the Constitution NwYh icshtu ddyid onf ott hceo mexm epnocset fwaicthto ac lcaousnessid eorfa titohne oCfo nCstaitludteiro nv'. Bull2 would not conform to good practice. The text writers and the commentators uniformly begin their treatment of ex post facto laws by citing it as the leading case, and setting forth its doctrine. There is singular agreement as to the correctness of the holding of the case.3 The statement given by Cooley is typical: "At an early day it was settled by authoritative decision, in opposition to what might seem the more natural and obvious meaning of the term ex post facto, that in their scope and purpose these provisions were confined to laws respecting criminal punishments, and had no relation whatever to retrospective legislation of any other description." 4 This doctrine of Calder v. Bull is so well settled as to have become one of the commonplaces of American constitutional law