Rhode Island v. Massachusetts - 37 U.S. 657 (1838)

Rule:

Jurisdiction is the power to hear and determine the subject matter in controversy between parties to a suit, to adjudicate or exercise any judicial power over them; the question is, whether on the case before a court, their action is judicial or extra-judicial; with or without the authority of law, to render a judgment or decree upon the rights of the litigant parties. If the law confers the power to render a judgment or decree, then the court has jurisdiction; what shall be adjudged or decreed between the parties, and with which is the right of the case, is judicial action, by hearing and determining it.

Facts:

At the January 1832 term of this Court, the plaintiff State Of Rhode Island And Providence Plantations filed a bill in equity, presenting a case arising under the various charters from the crown of England to the Plymouth Company in 1621, to Massachusetts in 1629, to Rhode Island in 1663, the new charter to Massachusetts in 1691 together with sundry intermediate proceedings of the council of Plymouth and the result of which was to vest in the colony of Massachusetts and the king, all the rights of propriety and government previously granted to that company as a political corporation. The bill also set out the repeal of the original charter of Massachusetts on a scire facias in the court of chancery in England, the grant by the crown and acceptance by the colony of a new charter, subsequent to the charter to Rhode Island. All these acts are specially and at large set out in the bill, but need not in this stage of the cause be referred to by the Court in detail. They present the claim of the plaintiff to the territory in controversy between the two states, in virtue of these charters, according to the boundaries therein described. Independently of the claim under the charter of 1663, the plaintiff asserted a previous right in virtue of grants from the Indians, and settlements made under a title thus acquired; and also asserts, that under both titles, the inhabitants of plaintiff made settlements on the lands immediately south of the boundary between the two colonies as now asserted. The prayer of the bill was to ascertain and establish the northern boundary between the states, that the rights of sovereignty and jurisdiction be restored and confirmed to the plaintiffs, and they be quieted in the enjoyment thereof, and their title; and for other and further relief. The case was now before the court for consideration, on a motion by the defendant, to dismiss the bill for want of jurisdiction in the cause.

Issue:

Should the defendant’s motion to dismiss the bill for want of jurisdiction be granted?

Answer:

No.

Conclusion:

The Supreme Court held that it has jurisdiction over the bill filed by plaintiff state of Rhode Island against defendant state of Massachusetts. The court explained that jurisdiction was the power to hear and determine the subject matter in controversy between parties to a suit, to adjudicate or exercise any judicial power over them. That an objection to jurisdiction, on the ground of exemption from the process of the court in which the suit was brought, or the manner in which a defendant was brought into it, was waived by appearance and pleading to issue, however, the court ruled that when the objection goes to the power of the court over the parties, or the subject matter, the defendant need not, for he cannot give the plaintiff a better writ, or bill. The Supreme Court was one of limited and special original jurisdiction. Thus, its action must be confined to the particular cases, controversies, and parties over which the constitution and laws have authorized it to act, that any proceeding without the limits prescribed was coram non judice, and its action a nullity. And whether, want or excess of power was objected by a party, or is apparent to the Court, it must surcease its action, or proceed extra-judicially. The court held that this court exists by a direct grant from the people of their judicial power. The people of the States, as they respectively become parties to the Constitution, gave to the judicial power of the United States jurisdiction over themselves, controversies between States, between citizens of the same or different States, claiming lands under their conflicting grants, within disputed territory.