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Markham v. Allen

Supreme Court of the United States · 1946 · Civil Procedure

Civil ProcedureFederal jurisdictionProbate exceptionprobate exceptionfederal equity jurisdictionstate probate courtcustody of propertyadjudication of rights

Facts

The Alien Property Custodian issued a vesting order purporting to vest in himself the interests of German legatees in the estate of Alvina Wagner, whose will had been admitted to probate in California and whose estate was being administered there. Before that, six resident heirs had filed a state probate petition for determination of heirship, alleging the German legatees were ineligible as beneficiaries under a California statute and that the resident heirs should inherit instead. The Custodian then sued in federal district court seeking a declaration that the resident claimants had no interest in the estate and that he was entitled to the entire net estate after administration expenses, debts, and taxes. The district court declared the Custodian entitled to receive the net estate in distribution, and the court of appeals held the federal court lacked jurisdiction because the matter was within probate jurisdiction.

Issue

Whether a federal district court has jurisdiction over a suit by the Alien Property Custodian against an executor and resident heirs to determine the Custodian's right to share in a decedent's estate that is currently being administered in a state probate court. Also, whether the district court should have declined to exercise that jurisdiction because the suit involved issues of state law and related pending probate proceedings.

Rule

A federal court has no jurisdiction to probate a will or administer an estate, and it may not disturb property in the custody of a state court. But a federal court of equity may entertain suits by creditors, legatees, heirs, and other claimants against a decedent's estate to establish their claims, and it may adjudicate rights in property in state-court custody, so long as its judgment does not interfere with probate proceedings, assume general probate jurisdiction, or disturb the state court's possession except by requiring recognition of the right adjudicated. The mere need to interpret state law is not by itself a sufficient reason to withhold relief where Congress has conferred jurisdiction.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Oregon probate court, the estate of Lena Ortiz is being administered in Portland. In federal district court, Noah Benton sues the executor and two rival claimants, asking for a declaration that he is entitled to whatever residue remains after debts, taxes, and administration expenses are paid, and the complaint does not ask the federal court to supervise the estate's administration.

Does the federal court have subject-matter jurisdiction over Noah's suit under the probate exception doctrine?

Explanation. The majority drew a distinction between forbidden probate functions and permissible adjudication of claims. A federal court cannot probate a will or administer an estate, but it may entertain suits by heirs, legatees, creditors, and other claimants to establish their rights against an estate if the judgment does not interfere with probate proceedings, assume general probate jurisdiction, or disturb the state court's possession of estate property. A declaration of entitlement to the residue after administration is permissible.