Federal Law And State Courts: Who Applies What?

The US Constitution establishes a federal system of government, with power shared between the federal government and state governments, each with its own court system. State courts are bound to give effect to federal law and disregard state law in the event of a conflict. In some cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a valid excuse to decline jurisdiction. However, in cases like Testa v. Katt, the Supreme Court reversed the decision of the Rhode Island Supreme Court, which had declined to enforce a federal statute, stating that the state court must enforce the federal statute and that its policy of not enforcing penal statutes of other sovereigns was not a valid excuse.

State court refusal to hear federal claims

In the United States, state courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict. This is because federal law is considered the "supreme law of the land".

However, in some cases, state courts have refused to hear federal claims, and their refusal has been upheld by the Supreme Court. This is provided there is a valid excuse for declining jurisdiction.

For example, in the 1929 case of Douglas v. New York, N.H. & H.R. Co., the Supreme Court upheld a state law that allowed state courts to decline jurisdiction over both state and federal law claims when neither party was a resident of the state. Similarly, in Herb v. Pitcairn (1945), the Supreme Court upheld a state court's application of state venue laws to dismiss a case brought under federal law because the cause of action arose outside the court's territorial jurisdiction.

In the 2009 case of Haywood v. Drown, the Supreme Court considered a state statute that divested New York state courts of jurisdiction over suits seeking money damages from corrections officers. The Court held that the New York law violated the Supremacy Clause, emphasising that only a neutral jurisdictional rule will be deemed a "valid excuse" for departing from the assumption that state courts will hear federal claims.

In summary, while state courts generally have a duty to enforce federal law, there may be valid excuses for declining jurisdiction in certain cases, as demonstrated by the above examples.

State court enforcement of federal statutes

The US Constitution creates a federal system of government, with power shared between the federal government and the state governments. Both the federal and state governments have their own court systems.

State courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict. Federal law is considered the "supreme law of the land". State courts have a duty to grant the relief that federal law requires.

In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. The Court reasoned that the laws of the United States are binding on the citizens and courts of the several States. The Court held that "the State courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it".

In several cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a "valid excuse" to decline jurisdiction. For example, in Douglas v. New York, the Court upheld a state law that allowed state courts to decline jurisdiction over state and federal law claims when neither party was a resident of the state.

In the 2009 case of Haywood v. Drown, the Supreme Court reversed a decision by the Rhode Island Supreme Court, which had declined to enforce a federal statute containing a punitive damages provision. The US Supreme Court held that the Rhode Island court must enforce the federal statute, and that a state policy of not enforcing penal statutes of other sovereigns was not a "valid excuse".

State court jurisdiction over federal claims

State courts are presumed to have the power to hear any claim arising under federal or state law, except those falling under the exclusive jurisdiction of federal courts. This includes issues like patent and admiralty law, which are of national significance. Federal courts are courts of limited jurisdiction, and a plaintiff must find a constitutional or congressional basis for subject-matter jurisdiction for a federal court to hear a claim.

In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. The Court reasoned that the laws of the United States are binding on state courts and citizens, and that the United States is a "paramount sovereignty". The Court held that "the State courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it".

In several cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a "valid excuse" to decline jurisdiction. For example, in Douglas v. New York, N.H. & H.R. Co., the Court upheld a state law that allowed state courts to decline jurisdiction over both state and federal law claims when neither party was a resident of the state.

In the 2009 case of Haywood v. Drown, the Supreme Court considered a state statute that divested New York state courts of jurisdiction over suits under 42 U.S.C. § 1983. The Court held that the New York law violated the Supremacy Clause, and that state courts must hear federal law claims unless state law bars jurisdiction through a neutral rule of judicial administration that does not improperly burden federal claims.

State court's duty to apply federal law

In the United States, both the federal government and each of the state governments have their own court systems. The US Constitution, as the supreme law of the land, creates a federal system of government in which power is shared between the federal government and the state governments.

State courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict. This includes not only the Constitution and laws and treaties but also the interpretations of their meanings by the United States Supreme Court. State courts have a duty to apply federal law and cannot refuse to hear a category of federal claims when the court entertains state law actions of a similar nature.

In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. The Court reasoned that the laws of the United States are binding on the citizens and courts of the several States, and that the United States is a concurrent and paramount sovereignty within its jurisdiction. The Court thus held that state courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it.

However, in several cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a "valid excuse" to decline jurisdiction. For example, in Douglas v. New York, N.H. & H.R. Co., the Court upheld a state law that allowed state courts to decline jurisdiction over both state and federal law claims when neither party was a resident of the state. In another case, Testa v. Katt, the Rhode Island Supreme Court initially declined to enforce a federal statute containing a punitive damages provision, but the US Supreme Court reversed this decision, holding that the Rhode Island court must enforce the federal statute.

State court's dismissal of federal law claims

In the United States, state courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict. However, in several cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a "valid excuse" to decline jurisdiction.

For example, in Douglas v. New York, N.H. & H.R. Co., the Supreme Court upheld a state law that allowed state courts to decline jurisdiction over both state and federal law claims when neither party was a resident of the state. Similarly, in Herb v. Pitcairn, the Supreme Court upheld a state court's application of state venue laws to dismiss an action brought under federal law because the cause of action arose outside the city court's territorial jurisdiction. In Missouri ex rel. S. R. Co. v. Mayfield, the Supreme Court held that a state's application of the forum non conveniens doctrine to bar the adjudication of a federal claim brought by non-residents was constitutional, provided that the policy was enforced impartially.

In some instances, state courts have dismissed federal law claims due to their nature. For instance, in Testa v. Katt, the Rhode Island Supreme Court initially declined to enforce a federal statute containing a punitive damages provision, deeming the law penal in nature and stating that the "state need not enforce the penal laws of a foreign government." However, the U.S. Supreme Court reversed this decision, mandating that the Rhode Island court enforce the federal statute and asserting that a state policy of not enforcing penal statutes of other sovereigns was not a "valid excuse."

State courts may also treat state claims added to federal claims more seriously and will not dismiss a case solely because the federal claim is dismissed. In such cases, consumers may have better odds of success in state court, as state court standing rules are often more flexible than those in federal court. Furthermore, state courts are not bound by Article III's case or controversy requirement or other federal rules of judicial procedure.

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