Cecily Zamora
The US Constitution authorizes federal courts to hear cases arising under the Constitution, federal laws, and treaties. However, unless Congress provides exclusive federal jurisdiction, state courts may also hear cases involving federal law. This concurrent jurisdiction of state courts has been affirmed in Supreme Court cases like Charles Dowd Box Co. v. Courtney and Gulf Offshore Co. v. Mobil Oil Corp. State courts generally must hear federal law claims, including those under federal civil rights laws, unless a neutral rule of judicial administration bars them from doing so. The civil rights removal statute allows defendants to remove cases from state to federal court if their civil rights are denied or unenforceable in state court.
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What You'll Learn
Federal courts have exclusive jurisdiction over federal antitrust laws
In the United States, the Constitution establishes a federal system of government, where power is shared between the federal government and the state governments. Both federal and state governments have their own court systems, each with their own structure, judicial selection process, and types of cases heard.
Federal courts are courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes. In certain cases, the jurisdiction of state courts overlaps with that of federal courts, allowing some cases to be brought in either court system. 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.
Similarly, federal courts have exclusive jurisdiction over federal antitrust laws. This means that only federal courts can hear cases involving federal antitrust laws, even though Congress has not expressly stated this. Antitrust laws prohibit unlawful mergers and business practices, with the basic objective of protecting the process of competition for the benefit of consumers. The Sherman Act, for example, outlaws "every contract, combination, or conspiracy in restraint of trade" and any "monopolization, attempted monopolization, or conspiracy or combination to monopolize." The Clayton Act and the Federal Trade Commission Act are also relevant federal antitrust laws.
While federal courts have exclusive jurisdiction over federal antitrust laws, state attorneys general can still file suits to enforce both state and federal antitrust laws. Private parties can also file lawsuits in both state and federal courts against violators of state and federal antitrust laws. Federal antitrust laws provide for treble (triple) damages against antitrust violators to encourage private lawsuit enforcement.
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State courts can hear cases if federal courts have jurisdiction
In the United States, federal courts have jurisdiction over a range of cases, including criminal matters, bankruptcy, and specific areas such as tax, claims against the federal government, and international trade. Each federal district reflects this diversity in its courts. For instance, the Fifth Circuit, encompassing Texas, Louisiana, and Mississippi, has its Court of Appeals in New Orleans, Louisiana.
While federal courts hold jurisdiction in these areas, state courts can also hear cases if federal courts have jurisdiction. This principle is known as "diversity jurisdiction." Diversity jurisdiction allows a plaintiff from one state to file a lawsuit in federal court when the defendant is from another state. The defendant can also seek to "remove" the case from state court under the same principle. To exercise diversity jurisdiction, all plaintiffs must reside in different states than the defendants, and the "amount in controversy" must exceed $75,000. It is important to note that diversity jurisdiction does not apply to criminal cases; state courts handle state criminal prosecutions, while federal courts handle federal criminal cases.
The civil rights removal law is another statute that can lead to disputes between federal and state courts. This law authorizes the removal of any civil or criminal action initiated in a state court against a person who is denied or unable to enforce their civil rights in that state court. However, recent decisions have largely upheld a restrictive interpretation of this statute, making successful applications for removal under this law quite rare.
In conclusion, while federal courts have jurisdiction in specific areas, state courts can hear cases that fall under federal jurisdiction in certain circumstances, such as through diversity jurisdiction or in cases involving federal civil rights laws.
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Federal procedural rules don't apply in state courts
Federal procedural rules do not apply in state courts. The Federal Rules of Civil Procedure govern civil proceedings in the United States district courts. These rules were first adopted in 1938 and have been amended over time, with the latest changes made in 2024. The purpose of these rules is to ensure a just, speedy, and cost-effective resolution of civil cases.
While the Federal Rules of Civil Procedure apply to all US District Courts, individual courts may also issue their own rules that relate to specific procedural requirements. These local rules must be consistent with Acts of Congress and the Federal Rules of Civil Procedure. The Federal Rules of Criminal Procedure, on the other hand, govern criminal cases in federal courts.
In the context of conflicts between federal and state courts, the civil rights removal law stands out as the statute most open to federal-state court dispute. This law allows for the removal of any action, civil or criminal, from a state court if a person's equal civil rights are denied or cannot be enforced in that state court. However, recent decisions have largely confirmed a restrictive interpretation of this removal privilege, making successful resort to the statute quite rare.
It's important to note that federal courts can interfere with state court proceedings in exceptional circumstances. As clarified in Sprint Communications, Inc. v. Jacobs, federal forbearance under Younger is limited to specific types of state proceedings: ongoing state criminal prosecutions, particular state civil proceedings akin to criminal prosecutions, and civil proceedings involving orders essential to the state courts' judicial functions.
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State courts must hear federal claims
State and federal courts have different jurisdictions, with federal courts being courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes. State courts, on the other hand, have broader jurisdiction and can hear cases that arise under state law or in some cases, federal law.
The civil rights removal law authorizes the removal of any action, civil or criminal, which is commenced in a state court against a person who is denied or cannot enforce their right to equal civil rights. This law allows for cases that are based on federal civil rights law to be heard in state courts.
In the case of McKnett v. St. Louis & S.F. Ry. (1934), the United States Supreme Court held that the Federal Constitution prohibits state courts of general jurisdiction from refusing to hear cases solely because the suit is brought under federal law. Similarly, in the 2009 case of Haywood v. Drown, the Supreme Court considered a New York state statute that sought to divest state courts of jurisdiction over suits seeking monetary damages from corrections officers under 42 U.S.C. § 1983. The Court held that this statute violated the Supremacy Clause and that New York could not shut the courthouse doors to federal claims simply because they conflicted with local policy.
However, it is important to note that the removal statute's reference to "any law providing for... equal rights" has been interpreted narrowly by the courts. As a result, successful instances of relying on this statute to remove cases from state to federal court are rare.
There are several advantages to bringing federal claims in state court. State court juries may be more local and sympathetic to consumer claims, and state court filing fees may be lower. Additionally, state court judges may have more general law practice experience, as opposed to federal judges who often come from large law firms specializing in defense work.
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State courts can enforce rights created by federal law
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. While federal law now grants exclusive jurisdiction over bankruptcy cases to federal courts, this case set a precedent for state courts hearing federal claims.
However, it is important to note that state courts are not required to treat federal claims as federal courts would. The Supreme Court has clarified that state courts must hear federal claims that fall within their ordinary jurisdiction as prescribed by local laws. This means that state courts of general jurisdiction cannot refuse to hear a case solely because it involves a federal law. For example, in McKnett v. St. Louis & S.F. Ry., the Federal Constitution prohibited a state court from refusing to hear a case simply because it involved a federal law.
In summary, while state courts can generally enforce rights created by federal law, they may decline to do so in specific circumstances, such as when a valid excuse exists or when the claim falls outside their ordinary jurisdiction.
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Frequently asked questions
Yes, state courts can decide cases involving federal civil rights law. Unless federal courts have exclusive jurisdiction over a matter, state courts may hear cases over which federal courts would also have jurisdiction.
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" that does not improperly burden claims arising under federal law.
Yes, a federal civil rights case can be removed from a state court to a federal court. The civil rights removal law authorizes the removal of any civil or criminal action by a defendant who is denied or cannot enforce a right under any law providing for equal civil rights in a state court.
Federal civil rights laws include statutes that make it unlawful for any individual to use force or the threatened use of force to interfere with another person's housing rights due to their race, color, religion, sex, handicap, familial status, or national origin. Federal civil rights laws also cover hate crimes committed due to a person's actual or perceived religion, national origin, gender, sexual orientation, gender identity, or disability.
