Slocum v. Mayberry

Supreme Court of the United States · 1817 · Federal Courts

Federal CourtsFederal jurisdictionState court jurisdictionCustoms and embargo enforcementexclusive federal cognizanceseizures on land or waterreplevinfederal officer custody

Facts

A federal customs collector detained a vessel under the 11th section of an act enforcing the embargo laws, which authorized collectors to detain a vessel suspected of intending to violate the embargo until the President's decision could be had. The officer also held the cargo that was on board the vessel. The owner sought recovery of the cargo in a Rhode Island state court. The officer defended on the ground that the detention was under federal law and therefore outside state-court authority.

Issue

Whether a state court may entertain an action to recover cargo held by a federal customs officer when federal law authorized detention of the vessel, but did not specifically authorize seizure or detention of the cargo. More broadly, the question was whether the Rhode Island court violated or misconstrued federal law by exercising jurisdiction and rejecting the officer's defense.

Rule

When property is seized or detained under authority of the laws of the United States for federal forfeiture or other federal proceedings, state courts may not take the property out of the custody of the federal officer or court by replevin or similar process. But where federal law gives no authority to detain the particular property, the owner may seek relief in state court because state jurisdiction is not displaced.

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

In Savannah, a federal revenue inspector seized both a shrimping boat and its refrigerated catch under a federal statute expressly authorizing seizure of any vessel and onboard goods suspected of customs fraud for forfeiture proceedings in federal court. Before any forfeiture hearing occurred, owner Elena Torres filed replevin in a Georgia state court seeking immediate return of the catch.

Should the Georgia state court exercise jurisdiction over Elena's replevin action?

Explanation. When property is seized under authority of federal law for forfeiture or adjudication, federal courts have exclusive cognizance of the seizure, and a state court cannot take the property out of the officer's possession by replevin or similar process. The perishability of the goods does not create state-court power where federal law specifically authorizes seizure of the property itself. (Derived from Slocum v. Mayberry (1817).)