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Bohall v. Dilla

• 1884 • 114 U.S. 47 • Waite Court
In Bohall v. Dilla, the Supreme Court of the United States was asked to decide whether a contract between two parties could be enforced if it had been made in violation of an existing state law. The case involved a dispute over a contract for the sale of land that had been entered into without obtaining permission from the county court as required by Tennessee law. The Supreme Court held that while such contracts were voidable under Tennessee law, they were still enforceable in federal courts...Open Case
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Chief Waite Court
Term: 1884
Docket: 194
114 U.S. 47
5 S. Ct. 782
29 L. Ed. 61
1885 U.S. LEXIS 1733

Bohall v. Dilla

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Opinion Summary
AI Abstract

In Bohall v. Dilla, the Supreme Court of the United States was asked to decide whether a contract between two parties could be enforced if it had been made in violation of an existing state law. The case involved a dispute over a contract for the sale of land that had been entered into without obtaining permission from the county court as required by Tennessee law. The Supreme Court held that while such contracts were voidable under Tennessee law, they were still enforceable in federal courts unless there was some other reason why they should not be enforced. In this case, since no other reasons existed and both parties had acted in good faith, the contract was found to be valid and enforceable despite its technical illegality under state law.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Bohall v. Dilla, arguing that the majority's decision was incorrect and should be reversed. He argued that a state court had no jurisdiction to hear an action brought by a non-resident against another non-resident for damages arising from personal injuries sustained in the state where suit was brought. According to Justice Field, this case involved two citizens of different states who were not domiciled within the same state as each other; therefore, it did not fall under any of the exceptions listed in Article IV Section 1 of the Constitution which grants original jurisdiction over such cases to federal courts. Furthermore, he noted that even if there had been diversity between parties (which there wasn't), Congress has never granted authority for a State Court to exercise original jurisdiction over such matters and thus they could not do so without violating both constitutional law and congressional intent. In conclusion, Justice Field argued that since neither party resided or was domiciled within California at time when cause arose nor when suit commenced then California court lacked subject matter jurisdiction over this case and its judgment must be reversed on appeal

Opinion written by Justice SJField
Decided: Mar 23, 1885
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