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Black, Administrator v. Thorne & Another

• 1883 • 111 U.S. 122 • Waite Court
Black, Administrator v. Thorne & Another was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of mandamus to a federal court. The case involved a dispute between the administrator of the estate of a deceased person and the executors of the estate. The administrator sought to have the executors removed from their positions and the state court issued a writ of mandamus to the federal court to do so. The Supreme Court held...Open Case
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Chief Waite Court
Term: 1883
Docket: 231
111 U.S. 122
4 S. Ct. 326
28 L. Ed. 372
1884 U.S. LEXIS 1765
Argued: Jan 24, 1884

Black, Administrator v. Thorne & Another

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Opinion Summary
AI Abstract

Black, Administrator v. Thorne & Another was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of mandamus to a federal court. The case involved a dispute between the administrator of the estate of a deceased person and the executors of the estate. The administrator sought to have the executors removed from their positions and the state court issued a writ of mandamus to the federal court to do so. The Supreme Court held that the state court did not have the authority to issue a writ of mandamus to a federal court. The Court reasoned that the writ of mandamus was a form of judicial power and that the state court did not have the authority to exercise such power over a federal court. The Court further held that the writ of mandamus was a form of judicial power that could only be exercised by a federal court. The Court's decision in this case established the principle that state courts do not have the authority to issue writs of mandamus to federal courts. This decision has been cited in numerous subsequent cases and has been used to support the principle that state courts do not have the authority to exercise judicial power over federal courts.

Dissent Summary
AI Abstract

In Black, Administrator v. Thorne & Another, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a non-resident against another non-resident in regards to property located within the state. The majority opinion held that such jurisdiction did exist and affirmed the decision of the lower court. However, Justice Field dissented from this opinion on two grounds: firstly, he argued that under Article IV of the Constitution it is only necessary for one party to be domiciled in order for there to be diversity jurisdiction; secondly, he argued that even if both parties were not domiciled within the same state then still there should have been no exercise of personal or quasi in rem jurisdiction by a State Court as it would violate due process rights guaranteed by Amendment XIV. In conclusion Justice Field believed that since neither party was domiciled within New York then they could not bring suit before its courts and thus their judgment should have been reversed.

Opinion written by Justice SJField
Decided: Mar 24, 1884
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