Murdock v. Memphis
Murdock v. Memphis is a significant legal case that addressed the limitations of federal jurisdiction over state law, particularly in the context of the U.S. Supreme Court's role in interpreting state constitutions. The case emerged from a dispute regarding whether the Court had the authority to review decisions made by a state's highest appellate court. Justice Samuel F. Miller, writing for a 5-3 majority, reinforced the idea that a state's top court is the ultimate interpreter of its own laws and constitution, a principle rooted in the Judiciary Act of 1789. The dissenting opinions highlighted differing views on the implications of congressional omissions in legislation. This case illustrates the complexities of dual federalism, where state and federal powers intersect and often lead to nuanced legal interpretations. The decision underscores the importance of state sovereignty in the American legal system, reflecting the delicate balance between federal and state judicial authority.
Murdock v. Memphis
Date: January 11, 1875
Citation: 87 U.S. 590
Issue: Dual federalism
Significance: The Supreme Court upheld a key provision of dual federalism.
Justice Samuel F. Miller wrote the opinion for the 5-3 majority, upholding the concept that a state’s top appellate court, not the U.S. Supreme Court, was the final arbiter of the meaning of that state’s constitution and laws. This was originally specified in the 1789 Judiciary Act, but that provision had been omitted from the 1867 amendment. The question was whether the congressional omission meant that the Court had state jurisdiction, but Miller found that such an important question could not be decided by congressional silence alone. The previous provision remained in effect. Justices Joseph P. Bradley, Nathan Clifford, and Noah H. Swayne dissented. Justice Morrison R. Waite did not participate.
![Woodcut representing the waterfront of Memphis, Tennessee. By engraved by John Filmer, based on a work by another artist (A. R. W.) (The American Cyclopædia, v. 11, 1879, p. 380) [Public domain], via Wikimedia Commons 95330119-92356.jpg](https://imageserver.ebscohost.com/img/embimages/ers/sp/embedded/95330119-92356.jpg?ephost1=dGJyMNHX8kSepq84xNvgOLCmsE2epq5Srqa4SK6WxWXS)
