Law School Case Brief
Sheldon v. Sill - 49 U.S. (8 How.) 441 (1850)
The political truth is, that the disposal of the judicial power, except in a few specified instances, belongs to Congress: and Congress is not bound to enlarge the jurisdiction of the federal courts to every subject, in every form which the Constitution might warrant.
The mortgagee, which was a Michigan bank, held the bond and mortgage executed by mortgagors, Thomas Sheldon and his wife, Eleanor Sheldon, who were Michigan residents. The bank assigned the bond and mortgage to Sill, the assignee, who was a New York citizen. He filed a bill to recover the amount of the bond and mortgage. The Sheldons pleaded in their answer that the circuit court had no jurisdiction because the instruments were originally given to a Michigan bank and that Sill stood in the bank's stead pursuant to § 11 of the Judiciary Act of 1789. The circuit court entered a decree in favor of Sill. The Sheldons sought review of the judgment.
Did the circuit court have jurisdiction to hear the case at bar?
The Court reversed the decree and remanded the cause to the circuit court with directions to dismiss the bill of complaint for want of jurisdiction. The Court stated that the Constitution had defined the limits of the judicial power of the United States, but it had not prescribed how much of it would be exercised by the circuit courts. Consequently, the statute which prescribed the limits of their jurisdiction could not be in conflict with the Constitution, unless it conferred powers not enumerated therein. The Court determined that Sill was the assignee of a "chose in action" within the meaning of § 11 of the Act, and as such, the circuit court had no jurisdiction because the assignor could not have brought an action in the circuit court.
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