Murdock v. City of Memphis

Supreme Court of the United States · 1875 · Federal Courts

Federal CourtsSupreme Court appellate jurisdictionReview of state-court judgmentsJudiciary ActAct of 1867state court reviewfederal questionindependent state ground

Facts

The City of Memphis conveyed the disputed land to the United States in 1844 by a general warranty deed for $20,000, with no purpose stated in the deed. After not building a navy yard and abandoning that purpose, the United States, by an 1854 act of Congress, ceded the property to the city for the use and benefit of the city. Murdock and others filed a chancery bill alleging the city originally held the title in trust for certain purposes, including a navy yard, and that when title returned from the United States the city held it in trust for them. The state courts dismissed the bill, rejecting that asserted trust claim and also confronting nonfederal issues in the case.

Issue

Does the second section of the Act of February 5, 1867 authorize the Supreme Court, once it has jurisdiction because a federal question was decided against the plaintiff in error in state court, to review and decide the entire case, including nonfederal questions? And, in this case, did the 1854 federal act give plaintiffs a right that the Tennessee Supreme Court wrongly denied?

Rule

Under the second section of the Act of 1867, the Supreme Court's appellate jurisdiction over state-court judgments is limited to the federal questions specified in the statute. The Court may examine the rest of the record only to determine whether an independent matter or issue already decided by the state court is sufficient to sustain the judgment despite any federal error; it may not review nonfederal questions for correctness.

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

Nina Patel sued Harbor Crest Storage in the Supreme Court of Oregon after a warehouse dispute in Portland. The Oregon Supreme Court rejected Nina's claim that a federal tariff statute gave her a defense and also held that, under Oregon contract law, her written release independently barred recovery.

On writ of error to the U.S. Supreme Court, the Court concludes the Oregon court misread the federal statute and that Nina's federal defense should have prevailed. What is the proper disposition?

Explanation. Under the majority rule, once a qualifying federal question is wrongly decided, the Supreme Court may inspect the rest of the record only to determine whether another issue actually adjudicated by the state court independently sustains the judgment. It may not review whether that state-law ruling was correct. If the release ruling is sufficient by itself, affirmance still follows.