Law School Case Brief
Murdock v. Memphis - 87 U.S. 590, 22 L. Ed. 429 (1874)
If a state court judgment was erroneously decided against a party, 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 the other matter. 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 the federal 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.
The grantors conveyed land to a city so that a U.S. naval depot could be built on the land. The U.S. paid the city for the land but then abandoned the site and conveyed the land to the city. The heir of the grantors sued to have the land subject to a trust in favor of the grantors. The trial court entered judgment for the city and the state supreme court affirmed. The heirs appealed the decision arguing that § 2 of the Act of Feb. 5, 1867 gave the U.S. Supreme Court jurisdiction to review the entire case, not merely the federal questions in the writ of error.
Does the U.S. Supreme Court have jurisdiction if the state supreme court correctly decided the federal question?
The Court held that Section 2 of the Act of Feb. 5, 1867, 14 Stat. 385, repealed by implication § 25 of the Judiciary Act, Act of Sept. 24, 1789, 1 Stat. 25, because the 1867 Act embraced the entire matter of U.S. Supreme Court review of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. It held that 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 decide the two issues of state law because the state Supreme Courts, rather than the federal courts, have final jurisdiction in the interpretation of state law.
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