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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:

The case involved an action brought in a Minnesota state court of first instance by the Fox Film Corporation against Muller, to recover damages for an alleged breach of two contracts by which Muller was licensed to exhibit certain moving-picture films belonging to Fox. Muller answered, setting up 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 dismissed the action. The Minnesota Supreme Court affirmed and 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. Furthermore, the state supreme court decided that the contracts violated the Sherman Anti-trust Act. Thereafter, Fox sought a writ of certiorari from the U.S. Supreme Court.

Issue:

Should the U.S. Supreme Court grant the writ of certiorari sought by Fox Film Corporation?

Answer:

No.

Conclusion:

The Court held that it lacked jurisdiction because the state court's judgment rested upon a non-federal ground, i.e. that the provisions of the contract were non-severable and thus if one provision was invalid, all others failed with it, which was a question of general and not of federal law, this was independent of the federal ground and adequate to support the judgment. Therefore, the Supreme Court dismissed Fox’s petition for review.

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