Riggs V. Palmer - Significance in Philosophy

Significance in Philosophy

Legal philosopher Ronald Dworkin uses Riggs in an argument against legal positivism, focusing on a version of positivism by H. L. A. Hart. As a leader of the philosophy of Legal Positivism, Hart argues that the decisions in this case should be based on existing law, which was silent on the issue at the time. Positivism holds that all legal decisions by courts are classified into one of two categories. Some are central to the legal rules at issue. In these cases, judges merely mechanically apply the rules which fall within their jurisdiction. The other category of decisions occupy the penumbra of legal rules, where the direction of the legal rule is unclear. In these cases, judges must decide which of the possible applications of the legal rules are best social policy and then apply the rule which is best.

Dworkin argues that Riggs has two features which contradict Hart's interpretation of the legal process. First, this case does not appear to lie at the edge of legal rules, instead it is very clearly central. Despite this, the majority did not apply the legal rule as required. Second, there appears to be a legitimate debate about what the law is, and not what the law should be, in this case. According to Dworkin, under most versions of legal positivism, Hart's included, there should rarely be debate about what counts as law.

In Taking Rights Seriously, Dworkin argues that this case shows that in addition to rules established in statutes, principles are also a component of law. These principles, while not binding in the same manner the rules can be, are sufficient to modify statutes as in Riggs. He argues that both the majority and the dissent use these legal principles -- "one cannot benefit from one's own wrongdoing" in the case of the majority and "one should not be punished beyond the ways specified in the statute" in the case of the dissent.