Anaya Nolan
The US Constitution states that unless federal courts have exclusive jurisdiction over a matter, state courts may hear cases over which federal courts would also have jurisdiction. In multiple cases, the Supreme Court has ruled that state courts must generally hear federal law claims unless a neutral rule of judicial administration prevents them from doing so. This means that state courts can enforce federal laws, including Section 1985, which prohibits conspiracies to deter or retaliate against witnesses in federal court proceedings through the use of force, threat, or intimidation.
| Characteristics | Values |
|---|---|
| Section 1985 Law | Conspiracy to interfere with civil rights |
| Support or Advocacy Clause | |
| Criminal punishment for intrastate conspiracies | |
| Preventing mob violence, torture, and intimidation of Black and Republican citizens | |
| Preventing conspiracies to deter, threaten, or intimidate witnesses or parties in federal court | |
| Protecting witnesses and parties from injury or property damage for attending or testifying in federal court | |
| Granting substantive federal right to prospective witnesses to be free from conspiracies or retaliation for attendance at federal court proceedings | |
| Providing remedies in damages for injuries or deprivation of federal rights resulting from conspiracies | |
| Authorizing private right of action and punitive damages | |
| State Court Enforcement | Generally must hear federal law claims unless barred by "neutral rule of judicial administration" |
| Authorized to hear claims but not required to agree to hear federal claims | |
| Have concurrent jurisdiction when competent to do so | |
| May decline jurisdiction if state law provides a "valid excuse" |
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What You'll Learn
Federal courts and state courts
Federal and state courts in the United States share power as outlined in the US Constitution, which establishes a federal system of government where power is shared between the federal government and state governments. Both the federal and state governments have their own court systems.
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 ruled that state courts could preside over cases arising under federal bankruptcy law. However, federal law now grants exclusive jurisdiction over bankruptcy cases to federal courts.
The Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a "valid excuse" to decline jurisdiction. For instance, 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.
While state courts may hear cases over which federal courts would have jurisdiction, they are not necessarily required to agree to hear federal claims.
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Conspiracy to interfere with civil rights
42 U.S. Code § 1985, or the Conspiracy to Interfere with Civil Rights statute, prohibits two or more persons in any state or territory from conspiring to deprive, either directly or indirectly, any person or group of persons of equal protection under the law. This includes conspiring to use force, intimidation, or threats to prevent citizens who are lawfully entitled to vote from doing so or expressing support for a candidate. The statute also prohibits conspiring to deter, through similar means, any party or witness in a US court from attending or testifying freely and truthfully, or influencing the verdict of a juror.
The origins of this statute can be traced back to the post-Civil War era, when reports of mob violence, torture, and intimidation of Black and Republican citizens prompted President Grant to urge Congress to enact legislation that would secure life, liberty, and property, as well as the enforcement of law across the nation. In response, Representative Samuel Shellabarger introduced a bill that served as a precursor to Section 1985(3), imposing civil liability and criminal punishment for various types of intrastate conspiracies.
Section 1985 has been invoked in modern times as well. In a case against then-presidential candidate Donald Trump's campaign committee, several individuals alleged that the campaign had conspired with Russian intelligence operatives who obtained the plaintiffs' personal information through a hack. The court, however, stated that Section 1985(3) is "purely remedial" and that the plaintiffs were alleging a First Amendment violation that required a showing of state action.
The statute outlines various punishments for violations, including fines, imprisonment, or both. The severity of the punishment depends on the specific circumstances and consequences of the conspiracy, such as whether bodily injury, death, kidnapping, or other aggravated circumstances are involved.
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The Support or Advocacy Clause
Section 1985, also known as the Conspiracy to Interfere with Civil Rights law, prohibits conspiracies that aim to deter, through force, threat, or intimidation, any party or witness from attending or testifying in federal court. It also addresses conspiracies that intend to injure any citizen or witness in their person or property due to their support or advocacy for a particular cause or their participation in legal proceedings.
State courts generally have the authority to hear federal law claims unless specific conditions apply. The Supreme Court has ruled that state courts are required to hear federal claims unless state law includes a "neutral rule of judicial administration" that does not impose a burden on federal law claims. This was affirmed in the 1876 case of Claflin v. Houseman, where the Supreme Court decided that state courts could preside over federal bankruptcy law cases.
However, the Supreme Court has also upheld state courts' refusal to hear federal claims in certain instances, such as in Douglas v. New York, N.H. & H.R. Co., where a state law allowed for the dismissal of claims when neither party was a state resident. This demonstrates that while state courts often have jurisdiction over federal claims, there are exceptions where valid excuses are presented.
In the context of Section 1985, lower courts have been divided on the interpretation of the law, specifically regarding the private right of action. The Support or Advocacy Clause, in particular, has been the subject of varying interpretations, as seen in the Cockrum court's misinterpretation of the Yarbrough case.
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Federal law claims
In the case of Haddle v. Garrison, the petitioner brought a federal claim under 42 U.S.C. 1985 and various state law claims. Section 1985 prohibits conspiracies to deter, by force, threat, or intimidation, any party or witness from attending or testifying in federal court or to injure any party or witness for having done so.
State courts have concurrent jurisdiction when they are competent to take it. While the Claflin case concerned when state courts may exercise jurisdiction over federal claims, subsequent cases have cited Claflin when considering when state courts can decline jurisdiction over federal claims. For example, in Douglas v. New York, 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.
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Supreme Court rulings
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. This ruling was made in the case of Howlett v. Rose (1990), where the Court decided that state courts could hear cases arising under federal bankruptcy law.
In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts had concurrent jurisdiction with federal courts and could hear cases arising under federal law. This was further supported by the rulings in Charles Dowd Box Co. v. Courtney (1962) and Gulf Offshore Co. v. Mobil Oil Corp. (1981). However, the Supreme Court has also upheld state courts' refusal to hear federal claims in certain circumstances. For example, in Douglas v. New York, N.H. & H.R. Co., the Court allowed state courts to decline jurisdiction over federal claims when neither party was a resident of the state.
In the context of Section 1985, which pertains to conspiracy to interfere with civil rights, the Supreme Court has made rulings regarding the separation of criminal and civil sanctions. During the 1883 revision of the United States Code, the Court analyzed the constitutionality of Section 5519, which involved the equal protection provision. In United States v. Harris, the Court concluded that Congress did not have the authority under the Thirteenth or Fourteenth Amendments to enact Section 5519 as it only authorized legislation restricting state action and not private conduct.
Additionally, in Haddle v. Garrison, the Court clarified that Section 1985 prohibits conspiracies to deter, threaten, or intimidate any party or witness from attending or testifying in federal court. It also protects the integrity of federal judicial proceedings and provides a remedy in damages for those injured in their person or property as a result of such conspiracies.
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Frequently asked questions
Section 1985 prohibits conspiracies to deter, by force, threat, or intimidation, any party or witness from attending or testifying in federal court or to injure a party or witness in their person or property for having done so. State courts may hear cases that federal courts have jurisdiction over unless state law bars a state court from hearing a federal claim through a "neutral rule of judicial administration".
Section 1985 was enacted based on the belief that state authorities were unwilling or unable to preserve civil order in the South during the Reconstruction. It grants prospective witnesses the substantive federal right to be free of conspiracies to deter or retaliate against them for their attendance at federal court proceedings.
Section 1985 applies to conspiracies to deter or intimidate any party or witness in federal court proceedings, as well as conspiracies to injure any citizen in the exercise of their legal rights, such as voting.
