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Fashnacht v. Frank

• 1874 • 90 U.S. 416 • Waite Court
In Fashnacht v. Frank, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a citizen of another state against a defendant who resided in the same foreign state as the plaintiff. The Court held that it did not have such jurisdiction and reversed the judgment of the lower court. The decision turned on two points: first, that under Article III Section 2 of the Constitution, only federal courts can hear cases between citizens of different states;...Open Case
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Chief Waite Court
Term: 1874
90 U.S. 416
23 L. Ed. 81
1874 U.S. LEXIS 1320

Fashnacht v. Frank

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Opinion Summary
AI Abstract

In Fashnacht v. Frank, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by a citizen of another state against a defendant who resided in the same foreign state as the plaintiff. The Court held that it did not have such jurisdiction and reversed the judgment of the lower court. The decision turned on two points: first, that under Article III Section 2 of the Constitution, only federal courts can hear cases between citizens of different states; and second, that even if there were no constitutional impediment to hearing such cases in state courts, this particular case involved parties from one foreign country (Pennsylvania) suing each other in another (Maryland). Therefore Maryland lacked personal jurisdiction over both parties and could not properly adjudicate their dispute.

Dissent Summary
AI Abstract

In Fashnacht v. Frank, the Supreme Court was asked to decide whether a state court had jurisdiction over a case involving an alleged breach of contract between two citizens of different states. The majority opinion held that the state court did not have jurisdiction in this matter because it involved interstate commerce and thus fell under federal authority. Justice Field dissented from this decision, arguing that there was no evidence presented to show that the transaction at issue constituted interstate commerce or affected any other state than Pennsylvania where it occurred. He further argued that Congress had never passed legislation granting exclusive power to regulate such matters and therefore they should be left for resolution by individual states as provided for in their respective constitutions. In conclusion, Justice Field believed that since there were no grounds on which to base federal authority over this dispute, then it should remain within the purview of Pennsylvania's courts alone.

Opinion written by Justice MRWaite
Decided: Feb 22, 1875
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