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Law School Case Brief

Murdock v. Memphis - 87 U.S. (20 Wall.) 590 (1874)

Rule:

If a state court judgment was erroneously decided against plaintiff in error, then the court must further inquire, whether there is any other matter or issue adjudged by the state court, which is sufficiently broad to maintain the judgment of that court, notwithstanding the error in deciding the issue raised by the federal question. If this is found to be the case, the judgment must be affirmed without inquiring into the soundness of the decision on such other matter of issue. But if it be found that the issue raised by the question of federal law is of such controlling character that its correct decision is necessary to any final judgment in the case, or that there has been no decision by the state court of any other matter or issue which is sufficient to maintain the judgment of that court without regard to the federal question, then this court will reverse the judgment of the state court, and will either render such judgment here as the state court should have rendered, or remand the case to that court, as the circumstances of the case may require.

Facts:

The grantors conveyed land to the city of Memphis so that a U.S. naval depot would be built on the land. The U.S. paid the city for the land, then abandoned the site and, pursuant to 10 Stat. 586, conveyed the land to the city. The heir sued to have the land subject to a trust in favor of the grantors. The trial court entered judgment for the city, and the Supreme Court of Tennessee affirmed. The heirs of the grantor thereafter sought a writ of error to review the judgment of the state supreme court, contending that  § 2 of the Act of Feb. 5, 1867 gave the United States Supreme Court jurisdiction to review the entire case, not merely the federal questions in the writ of error.

Issue:

Did § 2 of the Act of Feb. 5, 1867 give the United States Supreme Court jurisdiction to review the entire case, and not merely the federal questions in the writ of error?

Answer:

No.

Conclusion:

On appeal, the Court affirmed the decision of the trial court and the state supreme court. It held that Section 2 of the Act of Feb. 5, 1867, 14 Stat. 385, was repealed by implication § 25 of the Judiciary Act, Act of Sept. 24, 1789, 1 Stat. 25, because the 1867 Act embraced the entire matter of U.S. Supreme Court review of state supreme court decisions. According to the Court, the state supreme court correctly decided that the conveyance of the land under 10 Stat. 586 did not create a trust for the grantors. Thus, because the state supreme court correctly decided the federal question, the Court had no jurisdiction under 14 Stat. 385 to review any other matters in the record.

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