Texas v. Florida, 306 U.S. 398 (1039)

Texas v. Florida

No. 11, Original

Argued February 7, 1939
Decided March 13, 1939
306 U.S. 398

Syllabus

1. The Court inquires sua sponte into its jurisdiction of the case. P. 405.

2. Private parties whose presence is necessary or proper for the determination of a case or controversy between States may be joined as defendants. Id.

3. Jurisdiction of this suit under Constitution Art. III, § 2, turns on the questions whether the issue framed by the pleadings constitutes a justiciable "case" or "controversy" and whether the facts alleged and found afford an adequate basis for relief according to accepted doctrines of the common law and equity systems which are guides to decision of cases within the original jurisdiction of this Court. Id.

4. Bills of interpleader and bills in the nature of interpleader considered. Id.

5. The equitable jurisdiction by bill in the nature of interpleader exists where the parties, including the plaintiff, have independent and mutually exclusive claims upon the same fund and where, although in point of law or fact only one claimant is entitled to succeed, there is danger that independent prosecutions of the claims may result in multiple recoveries and resultant depletion of the fund to the damage of the claimant properly entitled. The ground of the jurisdiction is to avoid this danger. Equity avoids it by requiring the rival claimants to litigate before it the decisive issue. P. 406.

6. A suit, by bill in the nature of interpleader, brought by a State against other States to determine the true domicile of a decedent as the basis for death taxes, each State claiming the right to tax the succession to his intangible property upon the ground that he was there domiciled at the time of death, held cognizable in equity and within the original jurisdiction of this Court. Constitution Art. III, § 2. P. 405.

The sole legal basis asserted by each State for the right to impose the tax was domicile of the decedent, at the time of his death, in the taxing State; by the law of each, there could be but one domicile for death tax purposes; each in good faith claimed the domicile, and, prior to the suit, was in good faith preparing to enforce a tax lien upon decedent’s intangibles and, but for the suit, would be taking steps to that end; the net estate was insufficient to pay the tax claims of all the States and of the Federal Government; none of the States would consent to become a party to any proceeding in any of the others, to determine the right to tax; there was substantial basis for the claim of domicile in each of the States; and, due to the jurisdictional peculiarities of the federal and state judicial systems, and to the special circumstances of the case, there was a real risk that, through conflicting assessments aggregating an amount in excess of the estate, the right of the complainant or some other State might be defeated; no question was presented of a situs of any of the intangible property differing, for tax purposes, from the place of domicile, and no determination in this suit, as to domicile, could foreclose determination of such questions of other tax situs by any court of competent jurisdiction in which they might arise.

7. That two or more States may each constitutionally assess death taxes on a decedent’s intangibles upon a judicial determination that the decedent was domiciled within it, in proceedings binding upon the representatives of the estate, but to which the other States are not parties, is an established principle. P. 410.

8. The equity jurisdiction in a suit in the nature of interpleader being founded on avoidance of the risk of loss resulting from the threatened prosecution of multiple claims, the risk must be appraised in the light of the circumstances as they are in good faith alleged and shown to exist at the time when the suit was brought. P. 410.

9. In a suit like the present between States, mere adjudication suffices, and need not be supplemented by an injunction. P. 411.

10. The Court accepts the Special Master’s findings of fact and his conclusion that the decedent, at the time of his death, was domiciled in Massachusetts. P. 413.

11. Residence in fact, coupled with the purpose to make the place of residence one’s home, are the essential elements of domicile. P. 424.

12. While one’s statements may supply evidence of the intention requisite to establish domicile at a given place of residence, they cannot supply the fact of residence there, and they are of slight weight when they conflict with the fact. This is the more so where, as here, the statements are shown to have been inspired by the desire to establish a nominal residence for tax purposes, different from the residence in fact. P. 425.

In such circumstances, the actual fact of the place of residence and the person’s real attitude and intention with respect to it as disclosed by his course of conduct are he controlling factors in ascertaining his domicile. When one intends the facts to which the law attaches consequences, he must abide the consequences, whether intended or not.

13. One cannot elect to make his home in one place in point of interest and attachment and for the general purposes of life, and in another, where he in fact has no residence, for the purpose of taxation. P. 426.

14. Physical facts of residence, united with major life interests may fix domicile -- one’s "preeminent headquarters." Id.

15. The burden of proof is on one who claims that an earlier domicile was abandoned for a later one. P. 427.

Original suit by the Texas against the States of Florida, New York, and Massachusetts, to determine the domicile at death of Edward H.R. Green, deceased, as a basis for right to levy a death tax in respect of the succession to his intangible property. His wife and his sister, claimants upon the estate, were also impleaded as parties defendant. The defendant States separately denied the plaintiff’s claim of domicile in Texas, and each by counterclaim asserted its claim of domicile and consequent right to tax. The wife admitted that the decedent’s domicile was in Texas, and laid claim to a large share of the estate as community property free from death taxes. She was dismissed from the suit on stipulation. 302 U.S. 662. The sister denied the plaintiff’s claim of domicile in Texas and prayed that the true domicile for purposes of taxation be determined. The case was referred to John S. Flannery, Esq., as Special Master, who took voluminous evidence and made his report. He found that the domicile of decedent at the time of his death was in Massachusetts. The case was heard on exceptions to the Special Master’s conclusions of fact and subsidiary findings.