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Law School Case Brief

Tafflin v. Levitt - 493 U.S. 455, 110 S. Ct. 792 (1990)

Rule:

In considering the propriety of state-court jurisdiction over any particular federal claim, the court begins with the presumption that state courts enjoy concurrent jurisdiction. Congress, however, may confine jurisdiction to the federal courts either explicitly or implicitly. Thus, the presumption of concurrent jurisdiction can be rebutted by an explicit statutory directive, by unmistakable implication from legislative history, or by a clear incompatibility between state-court jurisdiction and federal interests.

Facts:

After the failure of a savings and loan association and the collapse of a state-chartered nonprofit corporation created to insure the savings and loan accounts, petitioners brought a civil action against respondents in federal court alleging violations of the Racketeer Influenced and Corrupt Organizations Act (RICO). The district court, granting respondents' motion to dismiss, held that (1) petitioners had failed to state a claim under federal securities legislation, and (2) because state courts have concurrent jurisdiction over civil RICO claims, federal abstention was appropriate for the other causes of action, since they had been raised in the pending litigation in state court. The appellate court affirmed the district court's decision. The Supreme Court of the United States affirmed.

Issue:

Did state courts have concurrent jurisdiction to hear civil claims under Racketeer Influenced and Corrupt Organizations Act (RICO)?

Answer:

Yes.

Conclusion:

State courts had concurrent jurisdiction to hear civil RICO claims because the language of RICO did not divest state courts of such jurisdiction. A review of RICO's legislative history revealed no evidence that Congress even considered the question of concurrent state court jurisdiction over RICO claims, much less any suggestion that Congress affirmatively intended to confer exclusive jurisdiction over such claims on the federal courts. The fact that Congress modeled RICO's remedial provision after 4 of the Clayton Act (15 U.S.C.S. 15(a)), which had been interpreted to confer exclusive jurisdiction on the federal courts, did not mean that Congress intended, by implication, to grant exclusive federal jurisdiction over claims arising under 1964(c). There was no clear incompatibility between state court jurisdiction over civil RICO actions and federal interests.

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