Federal Case Law: State Court Arguments?

The US Constitution creates a federal system of government, with power shared between the federal government and state governments, each with its own court system. The Supreme Court of the United States is the highest court and can decide appeals on cases brought in federal court or state court if they deal with federal law. State courts generally must hear federal law claims unless a state law bars a state court from hearing a federal claim through a neutral rule of judicial administration. Federal case law can be used to argue state cases, and vice versa, when there is an overlap in jurisdiction.

State court enforcement of federal law

The question of state court enforcement of federal law is related to, but distinct from, the anti-commandeering doctrine. In the case of Printz v. United States, the Supreme Court distinguished between federal control over state courts and commandeering of the political branches of state government. Justice Scalia's majority opinion surveyed federal legislation from early Congresses that required state courts to take certain actions, such as recording applications for citizenship. However, the Court noted that state courts are bound by the Supremacy Clause, which expressly requires them to apply federal law.

In another case, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. At the time, federal law did not yet grant exclusive jurisdiction over bankruptcy cases to federal courts. The Court reasoned that "the laws of the United States are laws in the several States, and just as much binding on the citizens and courts thereof as the State laws are."

In the case of Claflin v. Houseman, the Court sustained Congress's former practice, which gave state courts concurrent jurisdiction and prohibited the removal of cases begun in state courts to federal courts. When Connecticut courts refused to enforce an FELA claim, citing that it went against the state's public policy, the Court held that when Congress enacts a law and declares a national policy, that policy applies to all states.

The Supreme Court has ruled that state courts generally must hear federal law claims unless a 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 other words, a jurisdictional rule cannot be used to undermine federal law. This was demonstrated in the case of Testa v. Katt, where the Court held that state courts are required to enforce penal laws of the United States, even if the state considers the law to be penal in nature and 'foreign in the international sense'.

Federal control over state courts

Federal case law can be used to argue state cases, and federal law is supreme over state law. The US Constitution creates a federal system of government, with power shared between the federal government and state governments, and both have their own court systems.

The Supreme Court has ruled that state courts must hear federal law claims unless state law bars a state court from hearing a federal claim through a "neutral rule of judicial administration". This means that state courts are bound by the Supremacy Clause, which expressly requires them to apply federal law. The Court has also ruled that state courts can hear cases arising under federal bankruptcy law.

However, the Court has also shown a reluctance to interfere with state court proceedings except in extraordinary circumstances. In the case of Mondou v. New York, N.H. & H.R. Co., a Connecticut court declined to hear a case arising under federal law, citing a discrepancy in policy between the state and federal governments. The Supreme Court rejected this, stating that the case did not involve any attempt by Congress to enlarge or regulate the jurisdiction of state courts, but rather a question of when state courts must hear federal claims that fall within their ordinary jurisdiction, as prescribed by local laws.

In another case, the Rhode Island Supreme Court declined to enforce a federal statute containing a punitive damages provision, finding that the law was penal in nature and the state need not enforce the penal laws of a foreign government. The US Supreme Court reversed this decision, holding 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

The US Constitution establishes a federal system of government, with power shared between the federal government and state governments. Both the federal and state governments have their own court systems. State courts are considered courts of "general jurisdiction", meaning they hear all cases not specifically selected for federal courts. Federal courts have limited jurisdiction and can only hear cases in special circumstances.

State courts interpret and enforce state laws, and each state has the power to make and interpret its own laws. This helps the states retain power and prevents the national government from becoming too strong. State courts have the power to hear cases that arise in the state, except those prohibited by state law. For example, some states deny subject-matter jurisdiction for a case that does not involve state citizens and did not take place in the state.

Federal courts hear cases that raise a federal question and those involving diversity of citizenship. Federal questions involve the US government, the US Constitution, or other federal laws. For example, a federal court would hear a case about a violation of federal law, such as bank robbery, drug cases, or kidnapping. Federal courts also hear civil cases based on federal laws, such as laws prohibiting employment discrimination or regulating securities trading.

In some cases, state courts may hear cases over which federal courts would also have jurisdiction, unless federal courts have exclusive jurisdiction over a matter. The Supreme Court has 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. This means that state courts and federal courts can have concurrent jurisdiction over certain cases.

The question of state court enforcement of federal law is related to the anti-commandeering doctrine, which distinguishes between federal control over state courts and commandeering of the political branches of state government. State courts are bound by the Supremacy Clause, which requires them to apply federal law. However, this does not imply that Congress has the power to impress the state executive into its service.

Federal court interference with state courts

Federal case law can be used to argue state cases, but there are instances of federal court interference with state courts. Conflict between federal and state courts is inevitable when federal courts are open to persons complaining about unconstitutional or unlawful state action. However, rules of restraint flowing from the concept of comity reduce federal interference to a considerable degree.

In the aftermath of Dombrowski and Zwickler, there was a considerable expansion of federal court adjudication of constitutional attack through requests for injunctive and declaratory relief. However, these developments were highly controversial, and the Court in a series of 1971 cases circumscribed the discretion of the lower federal courts. Justice Black reviewed and reaffirmed the traditional rule of reluctance to interfere with state court proceedings except in extraordinary circumstances.

In deciding multiple cases on this issue, the Supreme Court has ruled that state courts generally must 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. For example, in the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law.

The question of state court enforcement of federal law is related to, but distinct from, the anti-commandeering doctrine. In Printz v. United States, the Supreme Court distinguished between federal control over state courts and commandeering of the political branches of state government. The Court concluded that early statutes imposing obligations on state courts do not imply a power of Congress to impress the state executive into its service.

Federal court jurisdiction

In the United States, federal courts are considered courts of limited jurisdiction, meaning they can only hear cases for which there is a constitutional or congressional basis for their authority. This is known as subject-matter jurisdiction, which dictates what a court can hear specifically. On the other hand, state courts are generally considered courts of general jurisdiction, allowing them to hear a broader range of cases arising under federal or state law. However, there are certain exceptions where federal courts have exclusive jurisdiction, such as bankruptcy cases.

The interplay between federal and state court jurisdiction can be complex. While federal courts generally have the authority to hear cases based on federal law, state courts may also hear federal law claims that fall within their "ordinary jurisdiction" as prescribed by local laws. The Supreme Court has ruled that state courts must generally hear federal law claims unless a neutral rule of judicial administration bars them from doing so without improperly burdening federal law claims. This ensures that cases are heard by courts with the appropriate expertise and roles.

Federal judges, including Supreme Court justices, are selected by the President and confirmed by the Senate. They typically hold their offices for life, but they can be impeached or choose to resign or retire earlier. Federal courts are organised into districts, with each district having at least one district judge appointed by the President. These district courts handle both civil and criminal trials within the federal court system.

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