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{{Short description|Principle of judicial interpretation of rules of procedure in legislative bodies}}
The '''enrolled bill rule''' is a principle of judicial interpretation of rules of procedure in [[Legislature|legislative]] bodies and [[rule of recognition]]. Under the doctrine, once a [[Bill (law)|bill]] passes a legislative body and is signed into law, the courts assume that all rules of procedure in the enactment process were properly followed. That is, "[i]f a legislative document is authenticated in regular form by the appropriate officials, the court treats that document as properly adopted."<ref>''United States v. Thomas'', 788 F.2d 1250 ([[7th Cir.]] 1986), ''[[certiorari|cert.]] denied'', 107 S.Ct. 187 (1986), citing ''Field v. Clark'', 143 U.S. 649, 36 L.Ed. 294, 12 S.Ct. 495 (1892).</ref>

==United Kingdom==
The doctrine was adopted  in ''[[The King v. Arundel]]''.<ref>{{cite BAILII | litigants=The King v. Arundel | court=EWHC | division=Ch | year=1616 | num=J11 | parallelcite=80 ER 258, (1617) Hobart 109}}</ref> It was based on the proposition that when an [[Acts of Parliament in the United Kingdom|Act]] was passed and assented to, it was affixed with the Great Seal, the "effective legal act of enactment".<ref>{{cite journal |url=http://www.columbia.edu/cu/jlsp/pdf/Winter%202007/sandler.pdf |pages=217–19 |journal=Columbia Journal of Law and Social Problems |title=Forget What You Learned in Civics Class: The "Enrolled Bill Rule" and Why It's Time to Overrule ''Field v. Clark'' |volume=41 |last1=Sandler |first1=David |access-date=2011-07-05 |archive-url=https://web.archive.org/web/20120129192124/http://www.columbia.edu/cu/jlsp/pdf/Winter%202007/sandler.pdf |archive-date=2012-01-29 |url-status=dead }}</ref> It was "a regal act, and no official might dispute the king's word".

The enrolled bill rule was restated by [[John Campbell, 1st Baron Campbell|Lord Campbell]] in ''Edinburgh & Dalkeith Railway Co v Wauchope''.<ref>{{cite BAILII | litigants=Edinburgh & Dalkeith Railway Company v Wauchope  | court=UKHL | division= | year=1842 | num=J12 | parallelcite=(1842) 1 Bell 278, 8 Cl & Fin 710, 8 ER 279 | date=22 March 1842}}</ref> In that case it was complained that the passage of a [[private bill]] was defective because proper notice had not been given. The House of Lords rejected the notion that the validity of an Act could be questioned.

==United States==
In the United States, the rule was adopted by the [[Supreme Court of the United States|Supreme Court]] in {{ussc|name=Field v. Clark|143|649|1892}}. In effect, the court ruled that the enrolled bill signed by the presiding officers of the two houses of Congress was the best evidence of what had been passed, being on balance better evidence than the journals of the respective houses, so it should not be called into question.<ref name=sandler/>

===State law===
At the time of the decision in ''Field'', nine states had adopted the doctrine, and thirteen had rejected it.<ref name=sandler>[http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=143&invol=649 143 U.S. 649].</ref> At least two states have weakened it:

*The [[Supreme Court of Kentucky]]<ref>''D&W Auto Supply v. Dept. of Revenue'', 602 S.W.2d 420 (Ky. 1980)</ref> has held that "there is a [[prima facie]] presumption that an enrolled bill is valid but such presumption may be overcome by clear, satisfactory and convincing evidence establishing that constitutional requirements have not been met".
*The [[Pennsylvania Supreme Court]] has limited the application of the doctrine.<ref>''Consumer Party of Pa. v. Commonwealth'', 507 A.2d 323 (Pa. 1986).</ref> It held, "When a law has been passed and approved and certified in due form, it is no part of the duty of the judiciary to go behind the law as duly certified to inquire into the observance of form in its passage", but the court also noted that "it would be a serious dereliction&nbsp;... to deliberately ignore a clear constitutional violation".

==See also==
* [[United States House Committee on Enrolled Bills]]
* [[Parliamentary sovereignty]]
* [[Bill of Rights 1689]], which prohibited proceedings in parliament (such as the form of passing bills) from being questioned outside of parliament

==References==
{{Reflist}}

{{DEFAULTSORT:Enrolled Bill Doctrine}}
[[Category:Common law legal terminology]]
[[Category:Legal doctrines and principles]]
[[Category:English legal terminology]]
[[Category:American legal terminology]]