Monday, February 11, 2013

Shoshone Mining Co. v. Rutter case brief

Shoshone Mining Co. v. Rutter case brief summary

177 U.S. 505

SYNOPSIS: Appellee mining company sought review of an order of the Circuit Court of Appeals for the Ninth Circuit, which held that federal jurisdiction existed in claims brought by appellant claimants under U.S. Rev. Stat. § 2326. Another adverse claim case was consolidated for review on the same issue.

-The claimants in two consolidated suits filed adverse claims under U.S. Rev. Stat. § 2326 to determine possession of land used for mining.
-The circuit court ruled that federal jurisdiction existed.

-On appeal, the U.S. Supreme Court reversed and held that U.S. Rev. Stat. §§ 2319, 2314, and 2332 expressly provided that the right of possession could be determined by local customs or rules of miners in the several mining districts insofar as they were applicable and not inconsistent with the laws of the United States.

-The recognition by Congress of local customs and statutory provisions as at times controlling the right of possession did not incorporate them into federal law.
-The Court pointed out that Congress left jurisdiction of those adverse suits in which the matter in controversy did not exceed $ 2000 in value in the state courts; thus, Congress did not intend to carve out a new jurisdiction for federal courts.
-Although adverse suits could sometimes present questions arising under the U.S. Constitution or laws where the federal courts had jurisdiction, the mere fact that a suit was authorized by federal statute was not in and of itself sufficient to confer federal jurisdiction.

OUTCOME: The Court reversed the order of the circuit court and remanded the adverse claim suit originally filed in federal court with instructions that the case should be dismissed. The second case, which was originally filed in state court and removed, was remanded to state court for further proceedings.

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