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, the Bank of Michigan, held the bond and mortgage executed by the mortgagors, Thomas C. Sheldon and his wife, Eleanor. The bank assigned the bond and mortgage to the assignee, William Sill, a New York citizen. Sill 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 the assignee 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 assignee, and decreed a sale of the mortgaged premises. Thereafter, the Sheldons appealed.
Does the circuit court, which entered a decree in favor of Sill, have jurisdiction to decide on the case?
The United States Supreme 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 that prescribed the limits of the federal courts' jurisdiction could not be in conflict with the Constitution, unless it conferred powers not enumerated therein. The Court determined that the assignee, a N.Y. resident, was the assignee of a "chose in action" of the assignor, the Michigan bank, 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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