Federal Jurisdiction

Duration of Federal Jurisdiction (Authority over Places Purchased)

A state may qualify its cession of territory by a condition that jurisdiction shall be retained by the United States only so long as the place is used for specified purposes.1 Such a provision operates prospectively and does not except from the grant that portion of a described tract which is then used as a railroad right of way.2 In 1892, the Court upheld the jurisdiction of the United States to try a person charged with murder on a military reservation, over the objection that the state had ceded jurisdiction only over such portions of the area as were used for military purposes and that the particular place on which the murder was committed was used solely for farming. The Court held that the character and purpose of the occupation having been officially established by the political department of the government, it was not open to the Court to inquire into the actual uses to which any portion of the area was temporarily put.3 A few years later, however, it ruled that the lease to a city, for use as a market, of a portion of an area which had been ceded to the United States for a particular purpose, suspended the exclusive jurisdiction of the United States.4

More about Federal Jurisdiction

The question arose whether the United States retains jurisdiction over a place that was ceded to it unconditionally, after it has abandoned the use of the property for governmental purposes and entered into a contract for sale to private persons. Minnesota asserted the right to tax the equitable interest of the purchaser in such land, and the Supreme Court upheld its right to do so. The majority assumed that “the Government’s unrestricted transfer of property to nonfederal hands is a relinquishment of the exclusive legislative power.” 5 In separate concurring opinions, Chief Justice Stone and Justice Frankfurter reserved judgment on the question of territorial jurisdiction.6

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References

This text about Federal Jurisdiction is based on “The Constitution of the United States of America: Analysis and Interpretation”, published by the U.S. Government Printing Office.

[Footnote 1] Palmer v. Barrett, 162 U.S. 399 (1896).

[Footnote 2] United States v. Unzeuta, 281 U.S. 138 (1930).

[Footnote 3] Benson v. United States, 146 U.S. 325, 331 (1892).

[Footnote 4] Palmer v. Barrett, 162 U.S. 399 (1896).

[Footnote 5] S.R.A., Inc. v. Minnesota, 327 U.S. 558, 564 (1946).

[Footnote 6] 327 U.S. at 570, 571.

Tables of Contents

• Federal Jurisdiction and other Topics in the Contents – Article 1 of the U.S. Constitution
• U.S. Constitutional Law Category
• List of amendments to the U.S. Constitution
• Federal Jurisdiction and other Topics in the Constitution Contents
• Interpretation of the U.S. Constitution (Table of Contents)
• Clauses of the Constitution (Table of Contents)

State Interference with Federal Jurisdiction

It seems settled, though not without dissent, that state courts have no power to enjoin proceedings 7 or effectuation of judgments 8 of the federal courts, with the exception of cases in which a state court has custody of property in proceedings in rem or quasi in rem, where the state court has exclusive jurisdiction to proceed and may enjoin parties from further action in federal court.9

Federal Jurisdiction and the U.S. Constitution

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References

This text about Federal Jurisdiction is based on “The Constitution of the United States of America: Analysis and Interpretation”, published by the U.S. Government Printing Office.

Notes

[Footnote 7] Donovan v. City of Dallas, 377 U.S. 408 (1964), and cases cited. Justices Harlan, Clark, and Stewart dissented, arguing that a state should have power to enjoin vexatious, duplicative litigation which would have the effect of thwarting a state-court judgment already entered. See also Baltimore & Ohio R.R. v. Kepner, 314 U.S. 44, 56 (1941) (Justice Frankfurter dissenting). In Riggs v. Johnson County, 73 U.S. (6 Wall.) 166 (1868), the general rule was attributed to the complete independence of state and federal courts in their spheres of action, but federal courts, of course may under certain circumstances enjoin actions in state courts.

[Footnote 8] McKim v. Voorhies, 11 U.S. (7 Cr.) 279 (1812); Riggs v. Johnson County, 73 U.S. (6 Wall.) 166 (1868).

[Footnote 9] Princess Lida v. Thompson, 305 U.S. 456 (1939). Nor do state courts have any power to release by habeas corpus persons in custody pursuant to federal authority. Ableman v. Booth, 62 U.S. (21 How.) 506 (1859); Tarble’s Case, 80 U.S. (13 Wall.) 397 (1872).