Gavin Howe
The United States Constitution establishes a federal system of government, where power is shared between the federal government and state governments. Both federal and state governments have their own court systems, each with their own structure, judicial selection, and types of cases heard. While federal courts have limited jurisdiction, hearing cases authorized by the Constitution or federal statutes, state courts may also hear cases that federal courts have jurisdiction over unless federal courts have exclusive jurisdiction. This means that there is an overlap in the jurisdiction of state and federal courts, and plaintiffs can choose to file a case in either court. However, the defendant may choose to remove the case to federal court if the plaintiff initially chooses to file in state court.
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What You'll Learn
- State courts can hear cases on federal laws unless federal courts have exclusive jurisdiction
- State courts can refuse to hear cases on federal laws if state law bars it
- The Supreme Court cannot hear cases decided entirely on state law
- State courts can hear cases on federal bankruptcy law
- State courts can hear cases on federal law claims
State courts can hear cases on federal laws unless federal courts have exclusive jurisdiction
In the United States, both the federal government and each of the state governments have their own court systems. While federal courts are courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes, state courts can hear cases on federal laws unless federal courts have exclusive jurisdiction.
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. Nevertheless, the Court's reasoning in Claflin v. Houseman established the principle that state courts have concurrent jurisdiction when they are constitutionally competent to take it.
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 the New York law violated the Supremacy Clause, emphasizing that only a neutral jurisdictional rule would be deemed a "valid excuse" for departing from the default assumption that state courts will hear federal claims.
While state courts generally must hear federal law claims, the Supreme Court has, in several cases, upheld state courts' refusal to hear federal claims on the basis of valid excuses provided by state law. 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 summary, state courts can hear cases on federal laws unless federal courts have exclusive jurisdiction. While there is a default assumption that state courts will hear federal claims, there may be valid excuses for state courts to decline jurisdiction, as determined by the Supreme Court on a case-by-case basis.
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State courts can refuse to hear cases on federal laws if state law bars it
In the United States, both the federal government and each of the state governments have their own court systems. While federal courts are courts of limited jurisdiction, meaning they can only hear cases authorized by the United States Constitution or federal statutes, state courts may hear cases over which federal courts would also have jurisdiction unless federal courts possess exclusive jurisdiction over a matter. For example, in the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. However, federal law now grants exclusive jurisdiction over bankruptcy cases to federal courts.
Although state courts may hear cases involving federal laws, they are not required to do so. State courts can refuse to hear cases on federal laws if state law bars it through a "neutral rule of judicial administration" that does not improperly burden claims arising under federal law. The Supreme Court has upheld state courts' refusal to hear federal claims in several cases, 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.
In another case, 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 city court's territorial jurisdiction. Similarly, in Missouri ex rel. S. R. Co. v. Mayfield, the Court held that a state's application of the forum non conveniens doctrine to bar the adjudication of a federal claim brought by nonresidents was constitutional as long as the policy was enforced impartially. These cases demonstrate that state courts can refuse to hear cases on federal laws if valid excuses or neutral rules of judicial administration justify their refusal.
It is important to note that the plaintiff has the initial choice of bringing the case in either state or federal court. However, if the plaintiff chooses a state court, the defendant may sometimes opt to "remove" the case to a federal court. This highlights the flexibility and complexity of the US judicial system, where the jurisdiction of state and federal courts can overlap, and cases can be transferred between court systems under specific circumstances.
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The Supreme Court cannot hear cases decided entirely on state law
The U.S. Constitution 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, with the Supreme Court being the highest court in the land.
The Supreme Court has original jurisdiction over certain cases, such as suits between two or more states, cases involving ambassadors, and other public ministers. It also has appellate jurisdiction on almost any other case that involves a point of constitutional and/or federal law. For example, cases where the United States is a party, cases involving treaties, and cases involving ships on the high seas and navigable waterways (admiralty cases).
While the Supreme Court can hear cases on federal laws, it cannot hear cases decided entirely on state law. In the case of Haywood v. Drown, the Supreme Court considered a state statute that divested New York state courts of jurisdiction over suits 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 would be deemed a 'valid excuse' for a state court to decline to hear federal claims.
In several other 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.
Therefore, while the Supreme Court can hear cases on federal laws, it cannot hear cases decided entirely on state law unless there is a violation of the Constitution or federal law.
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State courts can hear cases on federal bankruptcy law
In the United States, both the federal government and each of the state governments have their own court systems. While federal courts have exclusive jurisdiction over bankruptcy cases, state courts may hear cases over which federal courts would also have jurisdiction unless federal law provides otherwise.
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 binding on the citizens and courts of the several States and that the United States is a concurrent and paramount sovereignty within its jurisdiction. The Court thus held that "the State courts have concurrent jurisdiction whenever, by their own constitution, they are competent to take it."
However, in the 2011 case of Stern v. Marshall, the Supreme Court ruled that it was unconstitutional for Congress to grant bankruptcy courts jurisdiction over certain state law counterclaims as part of their "core" proceedings because bankruptcy judges lacked Article III protections. This ruling highlights the complex nature of federal jurisdiction over cases related to bankruptcy and the potential challenges to the constitutional authority of bankruptcy courts.
While state courts generally must hear federal law claims, the Supreme Court has upheld state courts' refusal to hear federal claims in certain cases, 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.
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State courts can hear cases on federal law claims
The United States Constitution establishes a federal system of government, with power shared between the federal government and state governments. Both federal and state governments have their own court systems. While federal courts are courts of limited jurisdiction, hearing cases authorized by the Constitution or federal statutes, state courts may also hear cases that fall under federal jurisdiction. This is known as "concurrent 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 federal laws are binding on citizens and state courts, and that the United States is a "concurrent sovereignty" with the states. This set a precedent for state courts having concurrent jurisdiction with federal courts in certain cases.
However, this does not mean that state courts are required to hear all 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. 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 when neither party was a resident of the state.
The Supreme Court has ruled that state courts generally must hear federal law claims unless state law includes a neutral rule of judicial administration that does not improperly burden federal claims. In the 2009 case Haywood v. Drown, the Court considered a New York state statute that divested state courts of jurisdiction over suits seeking damages from corrections officers. The Court held that this violated the Supremacy Clause, emphasizing that a neutral jurisdictional rule is required for a state court to decline hearing federal claims.
In summary, while state courts can hear cases on federal law claims, the specific circumstances will determine whether the case is heard in state or federal court. The plaintiff has the initial choice, but the defendant may sometimes choose to "remove" the case to federal court.
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Frequently asked questions
State courts may hear cases on federal laws unless federal courts have exclusive jurisdiction over the matter.
If a case is brought in state court, the defendant may sometimes choose to "remove" it to federal court.
Yes, if the case was decided by the highest court of a state, it can be appealed to the federal Supreme Court. However, the Supreme Court is not required to hear the appeal.
Yes, 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 the 2009 case Haywood v. Drown, the Supreme Court considered a New York state statute that divested state courts of jurisdiction over suits seeking money damages from corrections officers. The Court held that the New York law violated the Supremacy Clause and emphasized 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.
