ArtIII.S2.C2.3.2.3 State Interference with Federal Jurisdiction

Article III, Section 2, Clause 2:

In all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be a Party, the supreme Court shall have original Jurisdiction. In all the other Cases before mentioned, the Supreme Court shall have appellate Jurisdiction, both as to Law and Fact, with such Exceptions, and under such Regulations as the Congress shall make.

It seems settled, though not without dissent, that state courts have no power to enjoin proceedings 1 or effectuation of judgments 2 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. 3

Footnotes

  1.  Jump to essay-1Donovan 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.
  2.  Jump to essay-2McKim v. Voorhies, 11 U.S. (7 Cr.) 279 (1812); Riggs v. Johnson County, 73 U.S. (6 Wall.) 166 (1868).
  3.  Jump to essay-3Princess 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).