Federal Courts And State Law: Who Decides?

The U.S. Constitution establishes a federal system of government, with power shared between the federal government and state governments, each with its own court system. The Constitution grants federal courts limited subject-matter jurisdiction, with Article III outlining the Supreme Court's original jurisdiction. Federal courts can hear cases in law and equity arising under the Constitution, U.S. laws, and treaties, as well as admiralty cases and those between citizens of different states. State courts, on the other hand, have general jurisdiction, including concurrent jurisdiction over most constitutional and federal law issues. While federal courts have exclusive jurisdiction over certain matters, state courts may hear cases where federal courts also have jurisdiction unless state law bars it through a neutral rule of judicial administration. This dynamic raises questions about when state courts can enforce federal law and vice versa, with the Supreme Court providing key rulings for guidance.

State courts can hear federal bankruptcy cases

In the United States, federal courts have exclusive jurisdiction over bankruptcy cases. There are 90 U.S. bankruptcy courts, which are units of the U.S. district courts. Each of the 94 federal judicial districts handles bankruptcy matters, and in almost all districts, bankruptcy cases are filed in the bankruptcy court.

However, this was not always the case. 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 just as binding on the citizens and courts of the several States as state laws are.

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 2009 case Haywood v. Drown, the Supreme Court considered a state statute that divested New York state courts of jurisdiction over specific suits. The Court held that having made the decision to create courts of general jurisdiction that regularly sit to entertain analogous suits, New York could not refuse to hear federal claims that conflicted with its local policy.

In practice, bankruptcy courts oversee a process where a debtor, either a person or a business, is relieved of most debts and given the opportunity to repay creditors in an orderly manner. This can involve the liquidation of the debtor's assets or the creation of a repayment plan. Bankruptcy cases can involve litigation over matters such as who owns certain property, how much is owed on a debt, and whether the debtor should be discharged from certain debts.

Federal courts have limited subject matter jurisdiction

Federal courts are courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes. This is in contrast to most state courts, which are considered courts of general jurisdiction and are presumed to have the power to hear virtually any claim arising under federal or state law. To bring a case in federal court, a plaintiff must establish a constitutional or congressional basis for the court's subject-matter jurisdiction to hear the claim.

The two primary sources of subject-matter jurisdiction for federal courts are diversity jurisdiction and federal question jurisdiction. Diversity jurisdiction permits individuals to bring claims in federal court when the claim exceeds $75,000 and the parties are citizens of different states. Federal question jurisdiction allows an individual to bring a claim in federal court if it arises under federal law, including the U.S. Constitution, regardless of the value of the claim. For example, if a citizen of New York sues a citizen of California for $75,001, a federal court would have subject-matter jurisdiction to hear that claim under diversity jurisdiction.

Federal courts also possess exclusive jurisdiction over certain subject matters of national significance, such as patent and admiralty law. This exclusive jurisdiction reflects the federal government's substantial interest in these issues and facilitates the development of a uniform body of federal law to govern complex matters with interstate implications. Additionally, federal trial courts have been established for a few subject-specific areas, such as bankruptcy, tax, claims against the federal government, and international trade.

While federal courts have limited subject-matter jurisdiction, it is important to note that there is some overlap with state courts. In some cases, state courts may also have concurrent jurisdiction with federal courts, allowing parties the flexibility to choose the forum they believe will be most advantageous for their case. However, the limited jurisdiction of federal courts encourages parties to bring cases to state courts when appropriate, preventing excessive federal judicial intervention and ensuring claims are heard by courts most knowledgeable about the applicable law.

State courts have concurrent jurisdiction to hear cases involving the Constitution

The US Constitution establishes 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. The Constitution grants federal courts limited subject-matter jurisdiction, with the Supreme Court having original jurisdiction over several categories of cases.

While state courts have concurrent jurisdiction in many cases, there are times when they must defer to federal courts. 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 federal claims. In some cases, federal courts may require litigants to exhaust available remedies under state law before filing suit in federal court. Additionally, federal courts have exclusive jurisdiction over certain cases, such as federal criminal cases, admiralty cases, and certain cases involving seizures of property under federal law.

In summary, state courts have concurrent jurisdiction to hear cases involving the Constitution, but the specific jurisdiction of each court system can vary depending on the nature of the case and the laws involved.

Federal courts have exclusive jurisdiction over certain matters

Jurisdiction is the power or authority of a court to hear and decide a case. There are two types of jurisdiction: personal jurisdiction and subject-matter jurisdiction. While personal jurisdiction governs where the parties may be heard, subject-matter jurisdiction governs what the court can hear specifically. In federal court, a motion to dismiss for lack of subject-matter jurisdiction is considered a favored defence and may be raised at any point in the litigation process.

While federal courts have exclusive jurisdiction over certain matters, it is important to note that state courts are presumed to have the power to hear any claim arising under federal or state law, except those under the exclusive jurisdiction of federal courts. This means that state courts can generally hear a wide range of cases, including those that may involve federal law. In some cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a valid excuse for declining jurisdiction.

The division of jurisdiction between state and federal courts ensures that each court system addresses the types of cases best suited to their respective expertise and roles. This division also helps prevent excessive federal judicial intervention and channels claims into the most appropriate court. In certain instances, federal and state courts may have concurrent jurisdiction over the same case, allowing parties to choose the forum they believe will be most advantageous for their case.

State courts must hear federal law claims

In the United States, federal courts are courts of limited jurisdiction. Federal courts have exclusive jurisdiction over certain subject matters of national significance, such as issues like patent and admiralty law, and bankruptcy cases. In contrast, most state courts are courts of general jurisdiction and are presumed to have the power to hear virtually any claim arising under federal or state law, except those falling under the exclusive jurisdiction of federal courts.

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 just as binding on the citizens and courts of the several States as state laws are. The Court thus held that state courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it. While Claflin concerned when state courts may exercise jurisdiction over federal claims, subsequent cases have cited it when considering when state courts may validly decline jurisdiction over federal claims.

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. 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 Testa v. Katt, 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 U.S. Supreme Court reversed, 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.

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, emphasizing that only a neutral jurisdictional rule will be deemed a 'valid excuse' for departing from the default assumption that state courts will hear federal claims. Similarly, in McKnett v. St. Louis & S.F. Ry. Co., the Federal Constitution prohibited state courts of general jurisdiction from refusing to hear a case solely because the suit is brought under a federal law.

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