Overview
Gabriel Duvall (December 6, 1752 – March 6, 1844) was an American politician and jurist. Duvall was an Associate Justice of the Supreme Court of the United States from 1811 to 1835, during the Marshall Court. Previously, Duvall was the Comptroller of the Treasury, a Maryland state court judge, a member of the U.S. House of Representatives from Maryland, and a Maryland state legislator.
Whether Duvall is deserving of the title of "the most insignificant" justice in the history of the U.S. Supreme Court has been the subject of much academic interest, most notably a debate between University of Chicago Law Professors David P. Currie and (now-Judge) Frank H. Easterbrook in 1983. Currie argued that "impartial examination of Duvall's performance reveals to even the uninitiated observer that he achieved an enviable standard of insignificance against which all other justices must be measured." Easterbrook responded that Currie's analysis lacked "serious consideration of candidates so shrouded in obscurity that they escaped proper attention even in a contest of insignificance," and concluded that Duvall's colleague, Justice Thomas Todd, was even more insignificant.
Early and family life
Gabriel Duvall was born in Prince George's County in the Province of Maryland, as the sixth child of Benjamin Duvall (1719-1801) and his wife Susanna Tyler (1718-1794), both descendants of Mareen Duvall, Gabriel was born and raised on land that would eventually become known as Marietta. Two of his elder brothers died in the American Revolutionary War. Duvall read law to enter the bar in Prince George's County in 1778, and practiced in Anne Arundel and Prince George’s County at least part-time until 1823. In Annapolis, Maryland, he practiced in the Mayor's Court as county prosecutor beginning in 1781, and in Anne Arundel County court beginning in 1783, formally appearing in 600 cases by 1792 according to an archivist's research.
Some uncertainty remains over the spelling of Duvall's name. One scholar noted Supreme Court Reporters Cranch, Wheaton, and Peters uniformly spelled it "Duvall", but Marshall's biographer, Albert Beveridge, insisted on spelling the name with a single "l." Journalist and Supreme Court specialist Irving Lee Dilliard (1904–2002) concluded persuasively that the original "DuVal" or "Duval" employed in earlier generations had become "Duvall" before the future justice was born. Later family members used "DuVal".
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