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Law School Case Brief

Fox Film Corp. v. Muller - 296 U.S. 207, 56 S. Ct. 183 (1935)

Rule:

Where a judgment of a state court rests upon two grounds, one of which is federal and the other non-federal in character, the jurisdiction of the Supreme Court of the United States fails if the non-federal ground is independent of the federal ground and adequate to support the judgment. 

Facts:

A movie company brought an action against Muller, a licensee, in a Minnesota state court to recover damages for an alleged breach of two contracts by which Muller was licensed to exhibit certain moving-picture films belonging to the corporation. Muller’s defense was the invalidity of the contracts under the Sherman Anti-trust Act.

The state court held that each contract sued upon violated the Sherman Anti-trust Act and thus, was unenforceable. The state court dismissed the action. On appeal, the state supreme court affirmed. The state supreme court determined that the contracts were void on the ground that arbitration clauses that were concededly invalid were not severable from the other provisions of the contracts. A writ of certiorari was filed.

Issue:

Does the U.S. Supreme Court have jurisdiction over the case?

Answer:

No

Conclusion:

The Court dismissed the writ of certiorari for lack of jurisdiction, holding that it lacked jurisdiction because the state court's judgment rested upon a non-federal ground that was independent of the federal ground and adequate to support the judgment.

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