Johnson v. Fankell

520 U.S. 911, 117 S. Ct. 1800 (1997)

 

RULE:

Neither the United States Supreme Court nor any other federal tribunal has any authority to place a construction on a state statute different from the one rendered by the highest court of the state. This proposition, fundamental to our system of federalism, is applicable to procedural as well as substantive rules.

FACTS:

An individual who had been terminated from her employment as a liquor store clerk in Idaho brought an action in an Idaho state trial court against officials of the Idaho liquor dispensary. The individual, alleging that her termination had deprived her of property without due process of law in violation of the Federal Constitution's Fourteenth Amendment, sought to recover damages. The officials filed a motion to dismiss the individual's complaint on the ground that the officials were entitled to qualified immunity. However, the trial court, treating the motion as a motion for summary judgment because affidavits had been filed in support, denied the motion. On appeal, the Supreme Court of Idaho rejected the officials' arguments that (1) the order denying the officials' motion for summary judgment was final within the meaning of an Idaho appellate rule, and (2) the officials had a right to appeal as a matter of federal law.

ISSUE:

Did the Supreme Court of Idaho err in dismissing the state liquor officials' appeal?

ANSWER:

No

CONCLUSION:

The United States Supreme Court found that the Idaho Supreme Court's interpretation of a state statute was binding on federal courts, so its order was final. The Court also found that preemption was not appropriate where the right to immediate appellate review had its source in 28 U.S.C.S. § 1291, which did not apply in state court, and because the outcome would not be affected by postponement of the appeal until after final judgment.

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