Plaintiffs, justices of District of Columbia courts, protested the application by the Comptroller-General of an Act of Congress reducing their salaries, alleging that they felt it their duty to have the status of these courts defined. The majority of the Court, answering questions certified by the Court of Claims; held that section l of Article III of the federal constitution applied to the Supreme Court of the District of Columbia and to the Court of Appeals of the District of Columbia, and forbade a reduction of the compensation of the justices thereof during their continuance in office, on the theory that these are constitutional courts, since in creating them Congress acted under the dual authority of Article III and of section 8, Article I. Hughes, C. J., VanDevanter, and Cardozo, J. J., dissented. O'Donoghue v. United States, 289 U. S. 516, 53 Sup. Ct. 740 (1933).
CONSTITUTIONAL LAW--- STATUS OF COURTS OF DISTRICT OF COLUMBIA,
Mich. L. Rev.
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