ABSTRACT
One decision, Calder v. Bull, 3 US 386, had a long-term effect in one critical legal area, the prohibition against ex post facto laws, or "after the fact" laws. The first clause of Article 1, Section 10 of the Constitution, the Ex Post Facto Clause, forbids states from passing laws making previously legal acts illegal and punishing individuals for them. This ensures that citizens cannot be punished retroactively for an act that was legal when they did it but that later was made illegal. Calder began when the Connecticut state probate court rejected the will of Normand Morrison in 1793. Justice Samuel Chase noted the existence of the Fifth Amendment's Takings Clause, which prohibited government from taking private property without paying compensation. Chase went further in his opinion in stating that there were limits on government power not found in the Constitution.
