Gavin Howe
The question of whether state courts can enforce federal law is a complex one, relating to the anti-commandeering doctrine and the Supremacy Clause. While the Supremacy Clause presumes that state courts will interpret and be bound by federal law, there are instances where state courts have refused to hear federal claims, citing valid excuses such as state law or policy. In some cases, the Supreme Court has upheld these refusals, while in others, it has ruled that states cannot shut the courthouse door to federal claims that conflict with local policy. The Constitution's Vesting Clause also grants judicial power to the US Supreme Court and inferior courts established by Congress, but state courts may hear cases over which federal courts have jurisdiction unless the latter has exclusive jurisdiction.
| Characteristics | Values |
|---|---|
| State court enforcement of federal law | Related to, but distinct from, the anti-commandeering doctrine |
| State court jurisdiction | State courts have concurrent jurisdiction when they are competent to take it |
| Federal claims | State courts can hear cases over which federal courts would also have jurisdiction |
| Federal law | Is as much a part of the law of every state as its own local laws and constitution |
| State court enforcement of federal claims | State courts are bound to give effect to federal law when it is applicable |
| State court refusal to hear federal claims | Valid if state law provides a valid excuse to decline jurisdiction |
| State court refusal to hear federal claims | Invalid if the court entertains state law actions of a similar nature |
| State court enforcement of federal remedial laws | Approved by the Court, e.g., Charles Dowd Box Co. v. Courtney, 368 U.S. 502 (1962) |
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What You'll Learn
State courts must hear federal claims
In the United States, federal laws are binding on state courts and citizens, and the US is considered a concurrent and paramount sovereignty. This means that state courts have concurrent jurisdiction and can hear cases arising under federal law.
The rule that state courts must entertain federal claims does not imply that the state court should be treated as a federal court. In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. 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.
State courts may be more favourable to consumers bringing federal claims for a number of reasons. State court juries may be more local and sympathetic to consumer claims, and state court judges may have previous experience in general law practice, as opposed to federal judges who often come from large law firms that primarily do defence work. State court filing fees may also be lower.
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State courts can refuse federal claims
While state courts can hear cases over which federal courts have jurisdiction, they are not obligated to do so. The judicial Power of the United States is vested in the Supreme Court and inferior courts ordained by Congress. However, unless federal courts have exclusive jurisdiction over a matter, state courts may hear cases over which federal courts would also have jurisdiction.
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 individual states, and that the United States is not a foreign sovereignty in relation to these states. The Court concluded that "the State courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it."
However, the Supreme Court has also upheld state courts' refusal to hear federal claims in several cases, finding that state law provided a valid excuse for declining jurisdiction. 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. In Mondou v. New York, N.H. & H.R. Co., a Connecticut court declined to hear a case arising under federal law, in part because it held that it was "at liberty to decline cognizance of actions to enforce rights arising under [the federal] act."
State courts are generally bound to give effect to federal law when it is applicable and to set aside state law when there is a conflict. The Supremacy Clause requires state courts to follow the Supreme Court's interpretation of federal law and to grant the relief that federal law mandates. However, this does not imply that state courts must be treated as federal courts for the purpose of enforcing federal rights. The Supreme Court has acknowledged that state courts may have valid excuses for declining to hear federal claims, such as neutral rules of judicial administration.
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State courts and federal law
The Constitution's Supremacy Clause provides that the Constitution, federal statutes, and treaties shall be the supreme Law of the Land. This means that state courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict. The Supremacy Clause presumes that state courts will interpret and be bound 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 as much binding on the citizens and courts of the several States as the State laws are. The Court thus held that "the State courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it."
While the Claflin case 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. For example, in Douglas v. New York, the Court upheld New York's refusal to adjudicate an FELA claim that fell into a class of cases in which claims under state law would not be entertained.
In some cases, state courts are required to enforce federal law. For example, in Testa v. Katt, the Court unanimously held that state courts, at least with regard to claims and cases analogous to those enforceable under state law, are required to enforce "penal" laws of the United States. In other cases, such as McKnett v. St. Louis & S.F. Ry., the Federal Constitution prohibits state courts of general jurisdiction from refusing to hear cases brought under federal law.
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State court enforcement of federal law and the anti-commandeering doctrine
The question of state court enforcement of federal law is related to, but distinct from, the anti-commandeering doctrine. 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 the State laws are.
The Court thus held that "the 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, several subsequent cases have cited it when considering when state courts may validly decline jurisdiction over federal claims. In some cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a valid excuse to decline jurisdiction.
The anti-commandeering doctrine, which dates back to the 1842 case of Prigg v. Pennsylvania, holds that the Constitution forbids Congress from compelling the states to provide assistance in carrying out national law. In New York v. United States, the Supreme Court applied the anti-commandeering doctrine to state legislatures, and in Printz v. United States, the Court applied it to state executive officers. However, the Court has not yet applied the doctrine to state judiciaries, despite calls for it to do so.
In Printz, the Court noted that the Federal Government may neither issue directives requiring the States to address particular problems nor command the States' officers to administer or enforce a federal regulatory program. This principle was further upheld in Reno v. Condon, where the Court distinguished New York and Printz in upholding the Driver's Privacy Protection Act of 1994 (DPPA), a federal law that restricted the disclosure and resale of personal information contained in state motor vehicle records.
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State court enforcement of federal law and the Supremacy Clause
The United States Constitution's Supremacy Clause establishes federal law as superior to state law. This clause was a response to the absence of a similar provision in the Articles of Confederation, which governed the US from 1781 to 1789. During the Confederation era, federal statutes did not bind state courts unless state legislation implemented them. The Supremacy Clause was ratified in 1788, and it asserts that federal law is binding on state courts and citizens, just as state laws are.
The question of state court enforcement of federal law is related to, but distinct from, the anti-commandeering doctrine. State courts are required to entertain federal claims, but this does not imply that they are to be treated as federal courts. State courts may hear cases over which federal courts have jurisdiction unless the federal courts have exclusive jurisdiction. In the 1876 case of Claflin v. Houseman, the Supreme Court ruled that state courts could preside over cases arising under federal bankruptcy law.
The Supreme Court has interpreted the Supremacy Clause in the context of federal preemption, recognising several types of preemption. Federal law can expressly preempt state law when it explicitly states so, or it can be implied through the structure and purpose of the federal law. Field preemption occurs when federal law is so pervasive that Congress is assumed to have left no room for state supplementation, or when the federal interest is dominant.
In cases like Hines v. Davidowitz, the Supreme Court has suggested that state law is preempted when its application obstructs the objectives of a valid federal statute. This interpretation, known as the "Hines formulation," reflects a presumption about Congress's likely intent to preempt state laws that would hinder their purposes. However, some scholars argue that courts may not be in the best position to identify the full purposes and objectives behind federal statutes.
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Frequently asked questions
Yes, state courts can enforce federal law. The Constitution's Supremacy Clause provides that the Constitution, federal statutes, and treaties shall be the supreme Law of the Land, and the Judges in every State shall be bound by them. State courts are bound to give effect to federal law when it is applicable and to disregard state law when there is a conflict.
Yes, in some cases, state courts can decline to enforce federal law. While the Supremacy Clause presumes that state courts will interpret and be bound by federal law, there have been instances where state courts have refused to hear federal claims. For example, in Douglas v. New York, a state court declined to hear a case arising under federal law, and the Supreme Court upheld this decision.
The determination of whether a state court can decline to enforce federal law depends on various factors, including the nature of the claim, the jurisdiction of the state court, and the existence of a valid excuse. In some cases, state courts have been found to undermine federal law by distinguishing between different types of claims. For example, in New York, the court undermined the federal policy of making relief under Section 1983 broadly available by distinguishing between Section 1983 claims against corrections officers and all other Section 1983 suits.
