State Judges: Federal Law Violators Or Protectors?

The question of whether a state judge can violate federal laws is a complex one, involving the interplay between federal and state court jurisdiction and the ethical standards expected of judges. In the US, the judicial power is vested in the Supreme Court and inferior courts, with the laws of the US binding on the states and their citizens. While state courts may hear cases over which federal courts have jurisdiction, they are not obliged to do so in every instance. The Supreme Court has upheld state courts' refusal to hear federal claims in certain circumstances, such as when state law provides a valid excuse. However, in cases like Haywood v. Drown, the Supreme Court ruled that a state policy of not enforcing federal laws was not a valid excuse, citing the Supremacy Clause. Incidents of judicial misconduct, such as jailing people without due process or inventing improper remedies, can erode public trust and confidence in the judiciary, and ethical standards are in place to guide judges' conduct and preserve the integrity of the judiciary.

Can a State Judge Violate Federal Laws?

Federal court interference in state courts

The US Constitution states that the "judicial Power of the United States, shall be vested in one supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish." This establishes a system of federal courts that exist alongside state courts.

While federal courts generally cannot interfere with state court proceedings, there are some exceptions. For example, in the 1876 case of Claflin v. Houseman, the Supreme Court ruled that state courts could hear cases arising under federal bankruptcy law. However, federal law now grants exclusive jurisdiction over bankruptcy cases to federal courts.

In another case, Riggs v. Johnson County, it was established that federal courts may, under certain circumstances, enjoin actions in state courts. This was also seen in Princess Lida v. Thompson, where it was ruled that state courts do not have the power to release by habeas corpus persons in custody pursuant to federal authority.

The Supreme Court has also ruled that state courts must generally hear federal law claims unless state law bars a state court from hearing a federal claim through a neutral rule of judicial administration that does not improperly burden claims arising under federal law. In the 2009 case 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.

Federal courts have also been known to interfere in state court proceedings in cases where constitutional rights have been violated. For example, in Moore v. Dempsey, a case involving a conviction in a trial allegedly influenced by a mob, the Court directed a federal district judge to determine the merits of the petitioner's allegations.

State court jurisdiction to enforce federal law

The laws of the United States are binding on the citizens and courts of the individual states. The United States is not a foreign sovereignty with respect to the individual states but is a concurrent and paramount sovereignty within its jurisdiction. The U.S. Supreme Court has held that state courts have concurrent jurisdiction whenever they are competent to take it by their own constitution.

In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. At the time, federal law did not grant exclusive jurisdiction over bankruptcy cases to federal courts, as it does now (28 U.S.C. § 1334). The Court reasoned that the laws of the United States are binding on the citizens and courts of the individual states.

In Mondou v. New York, N.H. & H.R. Co., a Connecticut court declined to hear a case arising under federal law because the state court held that it was "at liberty to decline cognizance of actions to enforce rights arising under [the federal] act, because... the policy manifested by it is not in accord with the policy of the state." The Supreme Court rejected that proposition and held that the state court must hear the case. The Court emphasised that the case did not involve any attempt by Congress to enlarge or regulate the jurisdiction of state courts, or to control or affect their modes of procedure.

In St. Louis & S.F. Ry., the Court held that the Federal Constitution prohibits state courts of general jurisdiction from refusing to hear a case brought under federal law. In the 2009 case 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 seeking money damages from corrections officers. The Court held that the New York law violated the Supremacy Clause.

In Sprint Communications, Inc. v. Jacobs, the Court made clear that federal forbearance under Younger was limited to three types of state proceedings: (1) ongoing state criminal prosecutions; (2) particular state civil proceedings akin to criminal prosecutions; and (3) civil proceedings involving orders uniquely in furtherance of the state courts' ability to perform their judicial functions.

Federal and state court jurisdiction

The jurisdiction of federal courts in the United States is defined by the Constitution, congressional statutes, and decisions of the Supreme Court. The federal court system has three main levels: district courts (the trial court), circuit courts (the first level of appeal), and the Supreme Court of the United States (the final level of appeal). Federal courts are courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes. This type of jurisdiction is called ""original jurisdiction." The Constitution grants the Supreme Court original jurisdiction over cases affecting ambassadors and public ministers and cases in which a state is a party, leaving the remainder of cases within the judicial power to the Court's appellate jurisdiction.

The federal district court is the starting point for any case arising under federal statutes, the Constitution, or treaties. Sometimes, the jurisdiction of state courts will overlap with that of federal courts, meaning that some cases can be brought in both state and federal courts. For example, in cases where a plaintiff of one state wants to file a lawsuit against a defendant located in a different state, the plaintiff can choose to file in either state or federal court. This is known as "diversity jurisdiction."

State courts have concurrent jurisdiction with federal courts and can hear cases over which federal courts would also have jurisdiction unless the federal courts have exclusive jurisdiction over a matter. 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 other cases, the Supreme Court has held that a state policy of not enforcing federal laws was not a valid excuse and that state courts must enforce federal statutes.

While the federal and state court systems work differently in many ways, they both play a crucial role in enforcing the laws and ensuring justice is served. The federal court system handles cases that arise under federal law, while state courts handle cases based on state law, and in some instances, federal law. The federal court system also has specialized courts, such as bankruptcy courts and courts with nationwide jurisdiction for specific issues like tax and international trade.

State court enforcement of federal law

The laws of the United States are binding on the citizens and courts of the individual states. The United States is a concurrent and paramount sovereignty within its jurisdiction. The US Supreme Court has held that state courts have concurrent jurisdiction whenever they are competent to take it.

In the case of Claflin v. Houseman, the Court indicated that the states could not be compelled to enforce federal law. 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, the Supreme Court upheld New York's refusal to adjudicate an FELA claim, which fell into a class of cases in which claims under state law would not be entertained.

In the 2009 case of Haywood v. Drown, the Supreme Court considered a New York state statute that divested state courts of jurisdiction over suits seeking monetary damages from corrections officers. The Court held that the New York law violated the Supremacy Clause. The Court has also held that a jurisdictional rule cannot be used to undermine federal law, even if it appears even-handed. In the case of Testa v. Katt, the Court unanimously ruled that state courts must enforce the penal laws of the United States, at least with regard to claims and cases analogous to those enforceable under state law.

The Court has emphasised that only exceptional circumstances justify a federal court's refusal to decide a case in deference to the states. These circumstances include ongoing state criminal prosecutions, particular state civil proceedings akin to criminal prosecutions, and civil proceedings involving orders that are unique to the state courts' ability to perform their judicial functions.

Federal court refusal to decide a case in deference to the states

The US Constitution establishes a federal system of government, wherein power is shared between the federal government and the state governments. Both the federal and state governments have their own court systems. The judicial power of the US is vested in the Supreme Court and such inferior courts as Congress may establish.

The Supreme Court has original jurisdiction in cases affecting ambassadors, public ministers, and consuls, and those in which a state is a party. In all other cases, the Supreme Court has appellate jurisdiction, both as to law and fact, with such exceptions and under such regulations as Congress may make.

The Supreme Court has held that 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 a 2009 case, Haywood v. Drown, the Supreme Court considered a state statute that divested New York state courts of jurisdiction over suits seeking monetary damages from corrections officers. The Court held that the New York law violated the Supremacy Clause.

However, it is important to note that the Court has emphasized that "only exceptional circumstances justify a federal court's refusal to decide a case in deference to the States". In Sprint Communications, Inc. v. Jacobs, the Court clarified that federal forbearance under Younger was limited to three types of state proceedings:

• Ongoing state criminal prosecutions
• Particular state civil proceedings akin to criminal prosecutions
• Civil proceedings involving orders uniquely in furtherance of the state courts' ability to perform their judicial functions

In conclusion, while the Supreme Court has upheld the refusal of state courts to hear federal claims in certain circumstances, it has emphasized that this should only occur in exceptional cases. The Court has provided guidance on the types of cases that merit abstention, as outlined in the Sprint Communications case.

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