Cecily Zamora
The United States has two types of courts: state courts and federal courts. While federal court cases are more likely to impact national affairs, state courts handle more cases and interact with the public more frequently. State courts have general jurisdiction, meaning they can preside over all types of cases. In contrast, federal courts have limited jurisdiction and only hear matters involving federal questions and constitutional issues. State courts can rule on federal law, and in some cases, parties with federal law violations can choose between federal and state courts. However, the Supreme Court has upheld state courts' refusal to hear federal claims if state law provides a valid excuse.
Can state courts rule on federal law?
| Characteristics | Values |
|---|---|
| Types of courts in the U.S. | State courts and federal courts |
| Jurisdiction of state courts | General jurisdiction over all kinds of cases |
| Jurisdiction of federal courts | Limited jurisdiction over federal questions, constitutional matters, federal crimes, and civil lawsuits against the government |
| State court rulings on federal law | State courts can rule on federal law claims, but may decline jurisdiction if state law provides a valid excuse |
| Federal court rulings on state law | Federal courts cannot rule on state law claims |
| Impact of court rulings | Federal court rulings impact national affairs, while state court rulings are limited to the state |
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What You'll Learn
State court jurisdiction over federal law
In the United States, there are two types of courts: state courts and federal courts. While federal court cases are more likely to impact national affairs, state courts handle more cases and interact with the public more frequently.
State courts have general jurisdiction, meaning they have the authority to hear all kinds of cases. They have jurisdiction over state laws, criminal cases, and disputes between residents of the same state, and these cases are heard in the state where the incident occurred. Contract cases, family law matters, and traffic violations are also handled by state courts.
Federal courts, on the other hand, have limited jurisdiction and only hear matters involving federal questions and constitutional law. Federal crimes and civil lawsuits against the government are heard in federal district court.
In some instances, both federal and state courts have concurrent jurisdiction. This means that the same case can be heard in either a federal or state court, and it is up to the parties involved to choose which court will hear their case. For example, employees can go to either federal or state court for a federal law violation, such as a violation of the Family and Medical Leave Act.
However, there are situations where state courts may decline jurisdiction over federal claims. The Supreme Court has upheld the refusal of state courts to hear certain federal claims, finding that state law provided a valid excuse for declining jurisdiction. For instance, in the case of Testa v. Katt, the Rhode Island Supreme Court declined to enforce a federal statute with a punitive damages provision, deeming it penal in nature and not something the state was required to enforce.
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Federal court cases' national impact
While state courts do have the power to enforce federal law, the Supreme Court has upheld state courts' refusal to hear federal claims on the basis of state law providing a valid excuse. In the case of Haywood v. Drown (2009), the Supreme Court considered a New York state statute that sought to divest New York state courts of jurisdiction over suits under 42 U.S.C. § 1983 seeking money damages from corrections officers. The Court ruled that the New York law violated the Supremacy Clause, emphasising that only a neutral jurisdictional rule will be deemed a 'valid excuse'.
There have been numerous landmark cases in the United States Supreme Court that have had a national impact. One of the most significant is Marbury v. Madison (1803), which established the doctrine of judicial review. In this case, the Supreme Court asserted its power to declare legislative and executive actions unconstitutional, setting a precedent for the federal courts' ability to review and overturn laws and actions that contradict the Constitution.
Another notable case is McCulloch v. Maryland (1819), which established the principle of federal supremacy and recognised certain implied powers of the federal government. The Court held that regulating commerce is within the purview of the federal government and that state governments cannot enact their own commerce-regulating laws. This decision has had a lasting impact on the federal government's ability to regulate economic transactions.
The Dred Scott case in 1857, which denied African Americans the right to sue in federal court and upheld slavery, further fuelling the tensions leading up to the Civil War. The Plessy v. Ferguson case in 1896, where the Supreme Court sanctioned segregation by upholding the "separate but equal" doctrine, is another example of a case with national repercussions. The Court later reversed this decision in 1954, declaring that "separate schools are inherently unequal".
In the realm of education, the Supreme Court has also made significant rulings. In Brown v. Board of Education, the Court ruled against segregation in the Topeka, Kansas school system, marking a pivotal moment in the civil rights movement. The Court's decision in Cooper v. Aaron (1958) reinforced this, stating that states cannot nullify decisions of the federal courts, even if they believe the federal courts are violating the Constitution. Furthermore, the Court has ruled on student rights within schools, such as in Tinker, where it affirmed that students do not "shed their constitutional rights to freedom of speech...at the schoolhouse gate," setting a precedent for challenges to school-based First Amendment rights.
The Supreme Court has also weighed in on issues related to drug testing and free speech. In Board of Education of Independent School District #92 of Pottawatomie County v. Earls (2002), the Court held that random drug tests of students involved in extracurricular activities do not violate the Fourth Amendment. Additionally, in Bethel School District #43 v. Fraser (1987), the Court ruled that students do not have a First Amendment right to make obscene speeches in school, upholding the suspension of a student for delivering an obscene and provocative speech.
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State laws and their enforcement
State laws are enforced through a combination of public and private efforts. Federal law is also enforced by the states, with state attorneys general acting as agents of federal-state interaction. State enforcement of federal law is a unique model of enforcement, as it authorises state actors to enforce the laws of a different sovereign. This means that state enforcement authority can persist even in areas where state law is not in effect or state regulators have chosen not to act.
State enforcement is largely decentralised, and states act on behalf of interests that differ from those of federal enforcers. State attorneys general are independent from the state legislature and governor and may represent different constituencies. This opens up new avenues for state-centred policy, empowering actors whose interests and incentives set them apart from the state institutions that dominate other channels of federal-state dialogue.
State and local officials are responsible for defining and prosecuting crimes. They may also have the authority to enforce some federal laws, especially criminal laws. For example, state and local law enforcement officers can inquire about the status of an immigrant during the course of their normal duties in enforcing state and local law. This allows them to play an indirect role in enforcing federal immigration laws.
However, there are limits to the enforcement of federal laws by state courts. 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 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, emphasising 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.
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State court refusal to hear federal claims
In the United States, state courts have both the power and the duty to enforce federal law, unless federal courts have been given exclusive jurisdiction by Congress. However, there have been instances where state courts have refused to hear federal claims.
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 Supreme Court held that the New York law violated the Supremacy Clause, as it undermined the federal policy of making relief under Section 1983 broadly available. The Court emphasised that a "valid excuse" for a state court to depart from hearing federal claims would be if there was a neutral jurisdictional rule in place.
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. Similarly, in Herb v. Pitcairn, the Court upheld a state court's application of state venue laws to dismiss an action brought under federal law due to a lack of jurisdiction.
In addition, the Supreme Court has distinguished between federal control over state courts and commandeering of the political branches of state governments. In Printz v. United States, the Court made clear that while state courts are bound to enforce federal law, Congress cannot compel a state to create a forum to hear suits that would otherwise be unavailable under state law. This distinction highlights the delicate balance between federal and state powers in the US legal system.
It is worth noting that the question of when state courts must hear federal claims is related to their ordinary jurisdiction, as prescribed by local laws. This means that state courts are not required to hear every federal claim, but rather those that fall within their established jurisdiction.
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Federal vs. state court systems
The United States Constitution establishes a federal system of government, in which power is shared between the federal government and the state governments. Both the federal and state governments have their own court systems.
State courts are considered courts of "general jurisdiction", meaning they hear all cases that are not specifically selected for federal courts. State courts interpret state laws, and each state gets to make and interpret its own laws. This helps the states retain power and ensures that the national government does not become too strong. About 90% of all cases heard in the American court system occur at the state level. These include criminal cases that violate state law, such as robbery, assault, murder, and drug-related crimes; state constitutional controversies; state tax violations; real estate cases; malpractice; personal injury cases; contract disputes; and family, divorce, custody, inheritance, and probate cases.
Federal courts, on the other hand, have limited jurisdiction and can only hear cases in special circumstances. Federal courts generally hear cases that involve the United States government, the United States Constitution, or other federal laws. Examples include crimes that violate federal law, such as bank robbery, drug cases, gun crimes, or kidnapping; civil cases based on federal laws, such as employment discrimination laws or laws regulating securities trading; and cases involving foreign governments, international trade, or foreign treaties. Federal courts also hear cases that involve parties from two different states, referred to as "diversity jurisdiction".
In some situations, a case may qualify for either federal or state jurisdiction, and the plaintiff can choose where to file the lawsuit. The defendant may also have the option to request that a case initially brought in state court be removed to a federal court. It is important to note that state courts have concurrent jurisdiction and can hear federal claims that fall within their ordinary jurisdiction, as prescribed by local laws. However, in some cases, the Supreme Court has upheld state courts' refusal to hear federal claims, finding that state law provided a valid excuse for declining jurisdiction.
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Frequently asked questions
Yes, state courts can rule on federal law. The laws of the United States are binding on state courts, and state courts have concurrent jurisdiction over federal claims. However, federal courts have limited jurisdiction and only hear matters involving federal questions and constitutional matters.
It depends on the case. Federal courts hear matters involving federal law, federal crimes, and civil lawsuits against the government. State courts have general jurisdiction and handle criminal cases, disputes between residents of the same state, contract cases, family law matters, and traffic violations.
Federal court cases often involve matters of national importance, such as complex contract disputes, real estate, family law, personal injury, or employment. For example, in McKnett v. St. Louis & S.F. Ry. (1934), the Federal Constitution prohibited a state court from refusing to hear a case brought under federal law.
Yes, state governments may enact more restrictive laws than the Constitution and federal law, but they cannot enact laws that are less restrictive. For example, a federal law may establish employment leave requirements for businesses with more than 50 employees, but a state may have its own law that applies to fewer employees.
No, for a violation of state law, you would go to a state court. State courts have jurisdiction over state law matters.
