United States v. Lyon (1798)

United States v. Lyon was the first prosecution and conviction under the Sedition Act of 1798. In October 1798, sitting Congressman Matthew Lyon of Vermont was tried at Rutland before Supreme Court Justice William Paterson for published criticism of President John Adams, convicted, fined $1,000, and imprisoned four months in Vergennes — from where he was re-elected to Congress by a landslide, the only member of the House ever returned to office from a jail cell.¹² Released in February 1799 when supporters paid his fine in gold, Lyon announced, "I am on my way to Philadelphia," and returned to his seat.³ On July 4, 1840, Congress refunded the fine with interest, treating the conviction as having been imposed under an unconstitutional law.⁴

Main article on the defendant: [Matthew Lyon]

Background

On July 14, 1798, with war fever against France running high, President Adams signed the Sedition Act, criminalizing "false, scandalous and malicious" writing against the federal government, Congress, or the President.⁵ Matthew Lyon — Irish-born, formerly an indentured servant, founder of Fair Haven, and the only Democratic-Republican member of Congress from all of New England — was already the Federalists' most despised target: earlier that year he had spat at Connecticut's Roger Griswold and defended himself with fireplace tongs when Griswold attacked him with a cane on the House floor, the first physical brawl in House history.⁶⁷ Vermont itself was politically split east–west, and the Federalist establishment saw in Lyon the Act's ideal first defendant.²

Chronology

July 31, 1798 — The letter

Spooner's Vermont Journal (Windsor) publishes a letter from Lyon declaring that under the sitting administration "every consideration of the public welfare [is] swallowed up in a continual grasp for power," and charging the Executive with "an unbounded thirst for ridiculous pomp, foolish adulation, and selfish avarice."⁸ The letter had been written before the Sedition Act passed; it was published seventeen days after.²

October 1, 1798 — The Scourge

Shut out of Vermont's Federalist-aligned papers, Lyon launches his own magazine from Fair Haven: The Scourge of Aristocracy and Repository of Important Political Truths, with his son James Lyon as editor. Among its contents: a letter from the poet-diplomat Joel Barlow, which Lyon had also read aloud publicly, wondering why Congress had not committed the President "to a mad house."⁹

Early October 1798 — Indictment at Rutland

Within days of the opening of the U.S. Circuit Court session at Rutland, a grand jury indicts Lyon under the Sedition Act — counts resting on the Spooner's letter and the Barlow material.¹⁰²

October 1798 — Trial

Lyon is tried before Justice William Paterson, conducting his own defense on three grounds: that the court lacks jurisdiction because the Sedition Act is unconstitutional; that the publications were innocent; and that their contents were true.¹⁰ The constitutional argument is unavailing; truth as a defense fares no better.

October 9–10, 1798 — Verdict and sentence

The jury convicts. As the Vergennes Gazette reported, it "brought in their verdict of 'GUILTY' about nine."¹⁰ Paterson sentences Lyon to a $1,000 fine plus costs and four months' imprisonment — and rather than being held locally, the sitting congressman is marched under guard forty-four miles north to the jail at Vergennes, a distance widely read as deliberate humiliation.¹⁰¹¹ Vice President Jefferson, writing privately to Madison on November 3, observes that "the words called seditious were only general censures of the proceedings of Congress & of the President."¹¹

October–December 1798 — Imprisonment

Lyon is confined in an unheated cell and initially denied paper, pen, and heat; after public outcry, his jailers relent.¹² He continues to write, continues to publish the Scourge from inside the jail, and conducts a re-election campaign by letter.¹²²

December 1798 — Re-elected from jail

Vermont's voters return Lyon to Congress by a landslide — the first and only re-election of an imprisoned member of Congress in American history.¹² When furious supporters threaten to tear the Vergennes jail down, Lyon talks them out of it.¹

February 9, 1799 — Release

His fine paid — Virginia Senator Stevens T. Mason having traveled north carrying gold for the purpose — Lyon walks free declaring, "I am on my way to Philadelphia," and a flag-led procession accompanies him out of Vergennes toward Congress.¹⁷

February 22, 1799 — Expulsion fails

The House's second attempt to expel Lyon fails, 49–45. He keeps his seat.⁷

Aftermath

The prosecution did not end with Lyon. Anthony Haswell, the Bennington printer who published appeals in Lyon's defense, was himself convicted under the Sedition Act in 1800, fined, and jailed; his fine, too, was later remitted.² The Act expired by its own terms on March 3, 1801; incoming President Jefferson pardoned those still convicted under it and halted pending prosecutions.² In February 1801, when the deadlocked presidential election reached the House, Lyon cast Vermont's deciding vote for Jefferson on the 36th ballot.⁷¹

Politically, the case backfired on its authors: Lyon's martyrdom energized Vermont's Democratic-Republicans, sharpened the state's east–west divide, and made the Sedition Act a byword for overreach.²

The 1840 refund

On July 4, 1840, Congress passed "An Act to refund a fine imposed on Matthew Lyon," directing that his heirs be repaid the $1,000 with interest; the House Judiciary Committee's accompanying report treated the conviction as imposed under an unconstitutional law. The marginal note printed in the Statutes at Large reads: "A certain fine, with interest, to be refunded."⁴ The Supreme Court never ruled on the Sedition Act while it lived, but in New York Times Co. v. Sullivan (1964) the Court observed that "the attack upon its validity has carried the day in the court of history" — with the refund of Lyon's fine cited as evidence.¹³

See also

• [Matthew Lyon] — biography (main article on the defendant)
• Sedition Act of 1798
• Anthony Haswell (printer)
• Lyon–Griswold brawl (future event article)
• New York Times Co. v. Sullivan

External links

• The 1840 refund act, as printed (public domain): https://www.govinfo.gov/content/pkg/STATUTE-6/pdf/STATUTE-6-Pg802.pdf
• Jefferson to Madison, Nov. 3, 1798 — manuscript and transcription: https://founders.archives.gov/documents/Jefferson/01-30-02-0388
• Matthew Lyon Papers finding aid (incl. his letter attacking the Sedition Acts), Vermont Historical Society MSA 31: https://vermonthistory.org/documents/findaid/LyonMatthew.pdf
• Rachlin, the scholarly account of the case in its Vermont context: https://vermonthistory.org/journal/78/VHS7802SeditionAct1798.pdf