Anaya Nolan
The US Constitution establishes a federal system of government in which power is shared between the federal government and state governments, each with its own court system. While state courts handle most crimes that occur within a state's borders or within three miles of its coastline, there are circumstances in which a state law question can be prosecuted in federal courts. This includes crimes that violate federal law or involve a national or federal interest, such as federal tax fraud or immigration offenses. Additionally, diversity jurisdiction allows a plaintiff from one state to file a lawsuit in federal court if the defendant is from another state, and the amount in controversy exceeds $75,000. Federal courts can also hear cases where a crime violates both state and federal law, such as when a defendant moves a victim's body across state lines.
Can State Law Questions be Prosecuted in Federal Courts?
| Characteristics | Values |
|---|---|
| Cases based on state law can be brought in federal court | Under the court's "diversity jurisdiction", a plaintiff of one state can file a lawsuit in federal court when the defendant is located in a different state. |
| Diversity jurisdiction | The defendant can also seek to "remove" from state court for the same reason. |
| Diversity jurisdiction rules | To bring a state law claim in federal court, all plaintiffs must be located in different states than the defendants, and the "amount in controversy" must be more than $75,000. |
| Diversity jurisdiction and criminal cases | Criminal cases may not be brought under diversity jurisdiction. States may only bring criminal prosecutions in state courts, and the federal government may only bring criminal prosecutions in federal court. |
| Double jeopardy | The principle of double jeopardy – which does not allow a defendant to be tried twice for the same charge – does not apply between federal and state prosecutions. |
| Federal court prosecution | Crimes that violate federal law or involve a national or federal interest can be prosecuted in federal court. |
| Federal court prosecution examples | Federal tax fraud and immigration offenses are crimes that violate federal law. |
| State court prosecution | Most crimes that occur within a state's borders, or within three miles of its coastline, are prosecuted in state court by a state or district attorney. |
| State court jurisdiction | State law usually specifies which courts have jurisdiction over which types of cases. |
| State court jurisdiction examples | Adult felonies and misdemeanors are often divided between different courts. |
| State and federal court prosecution | A defendant can face prosecution for the same crime in both state and federal court. |
| State and federal court prosecution examples | A crime might occur partly on federal land and partly on non-federal land, giving both state and federal governments jurisdiction. |
| State and federal court prosecution examples | A crime might violate state law, such as murder, but moving the body across state lines makes it a federal crime. |
| State and federal court prosecution examples | The federal government might prosecute a case involving a large sex trafficking ring because of greater resources. |
| State court enforcement of federal law | The Supreme Court has ruled that 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". |
| State court enforcement of federal law examples | In the 1876 case of Claflin v. Houseman, the Supreme Court held that state courts could hear cases arising under federal bankruptcy law. |
| State court enforcement of federal law examples | In Mondou v. New York, N.H. & H.R. Co., a Connecticut court declined to hear a case arising under federal law, but the Supreme Court rejected this. |
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What You'll Learn
Federal court interference in state prosecutions
The US Constitution creates a federal system of government, wherein power is shared between the federal and state governments, each with its own court systems. However, federal courts are advised to refrain from interfering in state court prosecutions, especially when there are proceedings pending in them. This principle, according to Justice Black, stems from "Our Federalism", which requires federal courts to defer to state courts when proceedings are underway.
The federal courts' reluctance to interfere with state prosecutions is also based on the equity doctrine, which states that suits in equity "shall not be sustained in... the courts of the United States, in any case where a plain, adequate, and complete remedy may be had at law". This means that even if a state criminal statute is deemed unconstitutional, a person charged under it usually has the opportunity to raise a constitutional defence in the state trial.
The case of Sprint Communications, Inc. v. Jacobs clarified that federal forbearance is limited to three types of state proceedings: ongoing state criminal prosecutions, particular state civil proceedings akin to criminal prosecutions, and civil proceedings involving orders that support the state courts' judicial functions.
The expansion of federal court adjudication of constitutional attacks through injunctive and declaratory relief has been controversial. The Court in a series of 1971 cases limited the discretion of lower federal courts, emphasising that only exceptional circumstances justify a federal court's refusal to decide a case in deference to the states.
The New York City Bar Association's Task Force on the Rule of Law has denounced politically motivated federal legislative interference in state prosecutions of former President Donald Trump, asserting that the state courts and legislature should provide checks and balances to ensure fairness in criminal actions.
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Diversity jurisdiction
In the United States, federal and state governments share power, with each having its own court system. Diversity jurisdiction is a form of subject-matter jurisdiction that allows federal courts to hear lawsuits that do not involve a federal question.
For a federal court to have diversity jurisdiction over a lawsuit, two conditions must be met. Firstly, there must be "diversity of citizenship" between the parties, meaning the plaintiffs must be citizens of different states than the defendants. Secondly, the lawsuit's "amount in controversy" must exceed $75,000. If a lawsuit does not meet these conditions, federal courts generally lack jurisdiction unless it involves a federal question, in which case it would be heard in a state court.
The United States Constitution, in Article III, Section 2, grants Congress the authority to permit federal courts to hear diversity cases through legislation. Diversity jurisdiction is considered a form of concurrent jurisdiction, allowing parties to bring their case in state court even if the requirements for diversity jurisdiction are met. However, if diversity jurisdiction is available, a defendant in a state court case can unilaterally choose to move the case to federal court through the removal process.
The history of diversity jurisdiction has been marked by changes and debates. Before 1958, a corporation for diversity jurisdiction purposes was deemed a citizen only of the state in which it was incorporated. In 1866, Congress passed the Separable Controversy Act, allowing an out-of-state defendant sued by a resident plaintiff to remove a portion of the suit if it could be settled without all defendants. The act was amended a year later with the Local Prejudice Act, enabling any out-of-state party to petition for removal to a federal court upon asserting a fear of local prejudice in the state court.
The Supreme Court has also played a role in shaping diversity jurisdiction. In the 1806 case of Strawbridge v. Curtiss, the Court held that "complete diversity" was required, meaning that in cases with multiple parties, no plaintiff could share citizenship with any defendant. In Caterpillar, Inc. v. Lewis (1996), the Court ruled that federal jurisdiction based on diversity of citizenship could be sustained even if complete diversity did not exist at the time of removal, as long as it was present when the district court entered judgment.
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Federal court structure
The federal court system in the United States is structured with three main levels: district courts, circuit courts, and the Supreme Court. There are 94 district courts, 13 circuit courts, and one Supreme Court.
District courts, also known as trial courts, are the starting point for any case arising under federal statutes, the Constitution, or treaties. They handle both civil and criminal trials within the federal court system. Each district court has at least one United States district judge, who is appointed by the President and confirmed by the Senate for a life term. District court judges are responsible for managing the court and supervising its employees, and they can be impeached and removed by Congress if they fail to maintain "good behavior". In addition to district judges, there are also magistrate judges in each district court, who are appointed by a majority vote of the judges and serve a term of eight years if full-time and four years if part-time. Magistrate judges can oversee certain criminal cases, issue warrants, conduct initial hearings, set bail, and decide on certain motions.
The 13 appellate courts, or circuit courts, sit below the Supreme Court and are called the U.S. Courts of Appeals. These courts are responsible for determining whether the law was applied correctly in the trial court or federal administrative agency.
The Supreme Court of the United States is the highest court in the land and the final level of appeal in the federal system. Federal judges, including Supreme Court justices, are selected by the President and confirmed by the Senate. They typically hold their offices for life, although they may be removed by impeachment by the House of Representatives and conviction by the Senate.
The federal court system operates within a constitutional framework of "checks and balances", where each branch of the government (legislative, executive, and judicial) has its own roles and authority, and cooperation among the branches is often necessary. Federal laws, for example, are passed by Congress and signed by the President, but it is the judicial branch that decides the constitutionality of these laws and resolves cases involving them. While federal and state court systems exist separately, there is sometimes overlap in their jurisdiction, and certain cases can be brought in either federal or state court. For example, a plaintiff of one state may file a lawsuit in federal court under "diversity jurisdiction" if the defendant is located in a different state, and the defendant may choose to "remove" the case to federal court if it was initially brought in state court. However, criminal cases may not be brought under diversity jurisdiction.
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State court jurisdiction to enforce federal law
The US Constitution establishes a federal system of government, with power shared between the federal government and the state governments. Both federal and state governments have their own court systems.
In Mondou v. New York, N.H. & H.R. Co., a Connecticut court initially declined to hear a case arising under federal law, citing the discrepancy between federal and state policies. However, the Supreme Court overruled this decision, emphasising that Congress had not attempted to regulate state court jurisdiction or procedures. Instead, the case pertained to when state courts must hear federal claims within their ordinary jurisdiction as prescribed by local laws.
Similarly, in Testa v. Katt, the Rhode Island Supreme Court refused to enforce a federal statute with punitive damages, deeming it penal in nature and not a responsibility of the state. Once again, the US Supreme Court reversed this decision, stating that a state policy of not enforcing penal statutes of other sovereigns was not a valid excuse under Douglas.
The Judiciary Act of 1789 provided that civil actions initiated in state courts, which could have been brought in inferior federal courts, could be transferred to a federal court at the defendant's request. This expansion of removal jurisdiction has the potential for intra-court conflict, particularly in areas where federal court original jurisdiction is not mirrored in state courts.
While federal courts may exercise restraint in certain circumstances, such as ongoing state criminal prosecutions and specific civil proceedings, they are not bound by state court judgments on federal questions. Federal constitutional questions raised by state prisoners, for example, fall under federal habeas jurisdiction.
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Double jeopardy
The Fifth Amendment to the U.S. Constitution includes the Double Jeopardy Clause, which states that no person shall be "subject for the same offence to be twice put in jeopardy of life or limb". This clause, however, applies only to proceedings by the federal government, and double jeopardy does not protect a person from being prosecuted by both a state government and the federal government for the same act. This is due to the "'dual sovereignty' or "separate sovereigns" doctrine, which holds that each state government is distinct from the federal government, with its own laws, court systems, and sovereignty. Therefore, the same act can be considered a separate "offense" under each sovereignty, and each government can make its own determination about what to prosecute.
The "dual sovereignty" doctrine was invoked in the case of Rodney King, where officers of the Los Angeles Police Department were tried and acquitted of assault in a California state court in 1991. These officers were subsequently charged and convicted in federal court for violating Rodney King's civil rights, which was considered a separate offense from the state assault charge, and thus did not violate double jeopardy.
Another example of the "dual sovereignty" doctrine in action is the case of Gamble v. United States, where the Supreme Court voted 7-2 to uphold the concept of dual sovereignty. This case established that the federal government could prosecute a defendant who had already been acquitted of charges in state court, as long as the defendant's act violated both state and federal laws.
It is important to note that double jeopardy applies only to charges that were the subject of an earlier final judgment. For example, a retrial after a mistrial or a conviction that has been set aside on appeal is not considered double jeopardy, as there was no final judgment in the first trial. Additionally, charges that were dropped or put on hold can be reinstated in the future unless barred by a statute of limitations.
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Frequently asked questions
Cases that are entirely based on state law may be brought to federal court under the court's "diversity jurisdiction". Diversity jurisdiction allows a plaintiff of one state to file a lawsuit in federal court when the defendant is located in a different state. However, criminal cases may not be brought under diversity jurisdiction. States may only bring criminal prosecutions in state courts.
Crimes that violate federal law include federal tax fraud and immigration offenses.
Yes, a defendant can face prosecution for the same crime in both state and federal court. For example, in 1991, several Los Angeles police officers were acquitted of charges in state court in relation to the beating of motorist Rodney King. However, a federal grand jury indicted the officers for the same beating under a federal law.
Examples of state court cases include The People of the State of New York v. the Defendant or the State of Minnesota v. the Defendant.
