Gabriel Duvall

Who was Gabriel Duvall?

Gabriel Duvall 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 tenure of Chief Justice John Marshall. 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 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.