Samuel Freeman Miller (1816-1890), American jurist, was an associate justice of the U.S. Supreme Court.
Samuel F. Miller was born on April 5, 1816, in Richmond, Ky. He earned his medical degree at Transylvania University in 1838. While serving as a country doctor, he read law and was admitted to the bar in 1847. A Whig and a member of a Kentucky group advocating the end of slavery by gradual emancipation, Miller hoped the state constitutional convention of 1849 would advance this goal; instead, the institution of slavery was strengthened. In 1850 he left Kentucky and set up his law practice in Keokuk, Iowa.
Miller became a Republican and strongly supported Abraham Lincoln in the 1860 election. When a U.S. Supreme Court vacancy occurred, lowa Republicans sought the first west-of-the-Mississippi seat. Miller, an affable politician with no experience as a judge, was appointed in July 1862.
Like his colleagues on the Court, Miller did not seek to assert leadership in the critical Reconstruction racial issues, leaving those matters to Congress. However, his opinion in the Slaughter-House Cases (1873), which sustained an act of the Louisiana Legislature regulating the butchering business in New Orleans, was a landmark in the field of civil rights. The claim was made that the 14th Amendment protected individual butchers from having to agree to the rules of a state-authorized monopoly. Miller upheld the state government, stating that the 14th Amendment pertained only to the newly freed Negroes, who needed protection.
Soon, however, those who sought to curtail the advancement of Negroes reinterpreted Miller's decision. If a state could regulate the affairs of citizens who were butchers, they could do the same for citizens who were black. Once Southern legislatures had come back into the hands of racial conservatives, the Slaughter-House doctrine became a bastion of white supremacy. In Slaughter-House Miller had, somewhat unwittingly, given a new direction to American history: Reconstruction and Negro advancement faltered, while business interests were given strong impetus. In a less ambiguous civil rights decision, Ex parte Yarbrough (1884), Miller upheld, under the 15th Amendment, the right of a Negro to vote in a Federal election.
Miller unsuccessfully sought the chief justiceship in 1873. He was considered a Republican presidential possibility in both 1880 and 1884. He married twice and was the father of two children. He died on Oct. 13, 1890, in Washington, D.C., while still serving on the bench.
Further Reading on Samuel Freeman Miller
Charles Fairman, Mr. Justice Miller and the Supreme Court, 1862-1890 (1939), is a fine, occasionally uncritical biography. Miller is somewhat overpraised by William Gillette in Leon Friedman and Fred L. Israel, eds., The Justices of the United States Supreme Court, 1789-1969, vol. 2 (1969).