Massachusetts v. Missouri, 308 U.S. 1 (1939)

Massachusetts v. Missouri

No. ___, Original. Argued October 9, 1939

Decided November 6, 1939
308 U.S. 1

Syllabus

1. To constitute a controversy between two States, within the original jurisdiction of this Court, it must appear that the complaining State has suffered a wrong through the action of the other State, furnishing ground for judicial redress, or is asserting a right against the other State which is susceptible of judicial enforcement according to the accepted principles of the common law or equity systems of jurisprudence. P. 15.

2. A bill by one State against another State and citizens of the other which alleges that the plaintiff has assessed a tax on the transfer by death of the estate of one of its own citizens, the satisfaction of which depends upon resort to intangible assets of the decedent consisting of securities held by the individual defendants, as trustees, in the defendant State, and which alleges that the defendant State claims and will exercise a right to levy a like tax upon the transfer of this intangible property, and which prays to have the respective rights of the two States adjudicated, and for general relief, but which shows that the property is sufficient to answer the claims of both States and that the claims are not mutually exclusive, but independent, so that each State may constitutionally press its claim without conflict in point of law or fact with the decision of the other -- does not present a justiciable controversy between the two States. Texas v. Florida, 306 U.S. 398, distinguished. Id.

3. State statutes purporting to exempt from local transfer tax intangible assets of decedents who, at death, were citizens of other States which grant reciprocal exemptions create no enforceable obligation between the States enacting them. P. 16.

4. A State may not invoke the original jurisdiction of this Court to enforce the individual rights of its citizens. P. 17.

5. Federal jurisdiction to render a declaratory judgment depends on the existence of a controversy in the constitutional sense. Id.

6. A State cannot be brought into court by making its citizens parties to a suit not otherwise maintainable against the State. Id.

7. An action by a State to recover money from citizens of another State will not be entertained by the Court in the absence of facts showing that resort to the original jurisdiction is necessary for the protection of the plaintiff State. P. 18.

In the present instance, it does not appear that Massachusetts is without a proper and adequate remedy in the Missouri courts or the federal District Court in Missouri. P. 19.

8. Clause 2 of § 2 of Article III of the Constitution merely distributes the jurisdiction conferred by clause 1. Id.

9. The original jurisdiction of this Court, in cases where a State is a party, refers to those cases in which, according to the grant of power made in Art. III, § 2, cl. 1, jurisdiction might be exercised in consequence of the character of the party, and an original suit might be instituted in any of the federal courts. Cohens v. Virginia., 6 Wheat. 264. Id.

10. The objection that the courts in one State will not entertain a suit to recover taxes due to another, or upon a judgment for such taxes, goes not to the jurisdiction, but to the merits, and raises a question which the district courts are competent to decide. P. 20.

Motion for leave denied.

On motion for leave to file an original bill in this Court and the return to an order to show cause.