Supreme Court of the United States · 1833 · Federal Courts
Federal Courtsoriginal jurisdictionstate sovereign immunityadmiraltycustody of propertypersonal suit against a stateSupreme Court
Facts
The property at issue was not in the custody of a court of admiralty. It had not been brought within admiralty jurisdiction, and it was not in the possession of any private person. Instead, the claimant sought to recover proceeds that were in the possession of a state. The suit was therefore a personal demand against the state itself.
Issue
Whether a private person may commence an original suit in the Supreme Court against a state to recover proceeds in the state's possession by characterizing the matter as one within admiralty jurisdiction.
Rule
If the property is not in the custody of a court of admiralty, has not been brought within admiralty jurisdiction, and is not in the possession of a private person, the case is not one for the exercise of admiralty jurisdiction; when it is instead a mere personal suit against a state to recover proceeds in the state's possession, a private person has no right to commence an original suit in the Supreme Court against the state.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
Elena Ruiz, a cargo broker from Miami, claims that a shipment of coffee beans was sold by officials in Florida after a port dispute. She files an original action in the Supreme Court seeking the sale proceeds now held in Florida's treasury, alleging admiralty because the beans arrived by sea, but the cargo was never placed in the custody of any admiralty court.
How should the Supreme Court rule on Elena's attempt to proceed in admiralty?
Explanation. The controlling rule is that where the property is not in the custody of a court of admiralty, has not been brought within admiralty jurisdiction, and is not in the possession of a private person, the matter is not one for admiralty. In that circumstance, a claim seeking proceeds held by a state is a mere personal suit against the state, which a private person may not commence originally in the Supreme Court. (Derived from Ex parte Madrazzo (1833).)