Keith Mack
The US Constitution establishes a federal system of government, with power shared between the federal government and state governments, each with its own court systems. 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 and adjudicate federal claims. However, in certain cases, state courts may decline jurisdiction over federal claims based on valid excuses provided by state law or when the claim falls outside their ordinary jurisdiction. The usual course of action for individuals challenging the constitutionality of state actions is to bring suit in federal court, but suits can also be brought in state court.
| Characteristics | Values |
|---|---|
| State court enforcement of federal law | Related to, but distinct from, the anti-commandeering doctrine |
| State courts are bound by the Supremacy Clause, which requires them to apply federal law | |
| State courts are not bound by state court judgments on federal questions | |
| State courts have the power and duty to enforce federal law unless Congress gives federal courts exclusive jurisdiction | |
| State courts have concurrent jurisdiction when they are competent to take it | |
| State courts can refuse to hear federal claims if state law provides a valid excuse |
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What You'll Learn
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 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 some instances, state courts must hear federal claims that fall within their "'ordinary jurisdiction, as prescribed by local laws." The Federal Constitution prohibits state courts of general jurisdiction from refusing to hear a case solely because it involves a federal law. In Testa v. Katt, the Rhode Island Supreme Court declined to enforce a federal statute with punitive damages, deeming the law to be penal in nature. The court decided that the state need not enforce the penal laws of a foreign government.
In other cases, state courts have been found to have concurrent jurisdiction with 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 states as state laws are. However, federal law now grants exclusive jurisdiction over bankruptcy cases to federal courts.
In summary, state courts may hear cases over which federal courts have jurisdiction unless state law provides a valid excuse for declining jurisdiction. State courts must hear federal claims that fall within their ordinary jurisdiction, but they are not required to enforce penal federal laws. State courts have concurrent jurisdiction with federal courts in some cases, but federal law can grant exclusive jurisdiction to federal courts in certain matters.
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The anti-commandeering doctrine
In Printz v. United States, the Supreme Court differentiated between federal control over state courts and commandeering of the political branches of state governments. The Court's ruling was based on the Supremacy Clause, which mandates that state courts must apply federal law. The Court concluded that Congress does not have the authority to compel state executives to carry out its directives.
In Murphy v. National Collegiate Athletic Association (2018), the Supreme Court applied the anti-commandeering doctrine to congressional attempts to prevent states from taking certain actions. The Court ruled that the Professional and Amateur Sports Protection Act of 1992, which prohibited states that initially banned sports betting from legalising it, violated the anti-commandeering doctrine and invalidated the entire law. This case demonstrated the ongoing significance of the anti-commandeering doctrine in shaping the relationship between federal and state powers.
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Federal control over state courts
The US Constitution establishes a federal system of government, where power is shared between the federal government and the state governments. Both the federal and state governments have their own court systems.
The US Supreme Court has held that state courts are bound by the Supremacy Clause, which requires them to apply federal law. In the 1876 case of Claflin v. Houseman, the Supreme Court ruled 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 not a foreign sovereignty regarding the several States. The Court held that state courts have concurrent jurisdiction whenever they are competent to take it by their own constitution.
However, the Supreme Court has also upheld state courts' refusal to hear federal claims in certain circumstances. 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 Mondou v. New York, a Connecticut court declined to hear a case arising under federal law, as it held that it was not obligated to hear cases to enforce rights arising under federal law. The Supreme Court rejected this proposition and held that the state court must hear the case.
In summary, while the US Constitution establishes a federal system with shared powers between the federal and state governments, the Supreme Court has clarified that state courts are bound by the Supremacy Clause to apply federal law. The Court has provided guidance on when state courts may exercise jurisdiction over federal claims and has upheld state courts' refusal to hear federal claims in certain circumstances.
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State court jurisdiction over federal claims
In the United States, state courts have concurrent jurisdiction with federal courts over federal claims. This means that state courts can generally hear cases that arise under federal law. This principle was established in the 1876 case of Claflin v. Houseman, where the Supreme Court held that state courts could preside over cases concerning federal bankruptcy law.
However, there are exceptions to this rule, and state courts may decline jurisdiction over federal claims in certain circumstances. 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 court's territorial jurisdiction.
The Supreme Court has also distinguished between federal control over state courts and commandeering of the political branches of state governments. In Printz v. United States, the Court noted that while state courts are bound by the Supremacy Clause to apply federal law, this does not imply a power of Congress to impress the state executive into its service.
It's important to note that the question of state court enforcement of federal law is a complex legal issue, and the specific circumstances of each case can significantly impact the outcome. As such, it is always advisable to seek legal advice or consult a legal professional for clarification on specific situations.
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Federal court interference with state courts
The US Constitution establishes the independence of state and federal courts in their spheres of action. However, federal courts may, under certain circumstances, enjoin actions in state courts.
The Supreme Court has held that state courts are bound by the Supremacy Clause, which expressly requires them to apply federal law. In the 1876 case of Claflin v. Houseman, the Supreme Court ruled 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.
However, the Supreme Court has also 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.
Conflict between federal and state courts is inevitable when federal courts are open to persons complaining about unconstitutional or unlawful state action that could be brought in state courts. However, rules of restraint, such as the abstention doctrine and the equity doctrine, reduce federal interference to some degree.
The traditional rule, as reviewed and reaffirmed by Justice Black, is that federal courts should be reluctant to interfere with state court proceedings except in extraordinary circumstances. When prosecutions are pending in state court, the propriety of injunctive and declaratory relief should be judged by the same standards, as a declaratory judgment can interfere with state proceedings just as much as an injunction.
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Frequently asked questions
State and federal governments have their own court systems, and the US Constitution creates a federal system of government where power is shared between the federal and state governments. State courts are bound by the Supremacy Clause to apply federal law, and federal law is considered the supreme law of the land. However, federal courts do not have to abide by state court judgments on federal questions.
State courts can decline jurisdiction over federal claims if neither party is a resident of the state. Additionally, state courts can refuse jurisdiction if the cause of action falls outside the court's territorial jurisdiction.
Yes, one can challenge the constitutionality of state actions in state court or federal court. The usual course of action is to sue in federal court for an injunction or a declaratory judgment.
