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Gumbel v. Pitkin & Others

• 1884 • 113 U.S. 545 • Waite Court
Gumbel v. Pitkin & Others was a United States Supreme Court case that dealt with the issue of whether a state court could issue a writ of error to a federal court. The case was brought by the plaintiff, Gumbel, who was a citizen of Louisiana. He had brought a suit in the federal court against the defendants, Pitkin & Others, who were citizens of New York. The federal court had dismissed the suit, and Gumbel had appealed to the Supreme Court of Louisiana. The Supreme Court of Louisiana had...Open Case
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Chief Waite Court
Term: 1884
113 U.S. 545
5 S. Ct. 616
28 L. Ed. 1128
1885 U.S. LEXIS 1705

Gumbel v. Pitkin & Others

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Opinion Summary
AI Abstract

Gumbel v. Pitkin & Others was a United States Supreme Court case that dealt with the issue of whether a state court could issue a writ of error to a federal court. The case was brought by the plaintiff, Gumbel, who was a citizen of Louisiana. He had brought a suit in the federal court against the defendants, Pitkin & Others, who were citizens of New York. The federal court had dismissed the suit, and Gumbel had appealed to the Supreme Court of Louisiana. The Supreme Court of Louisiana had issued a writ of error to the federal court, but the federal court refused to accept it. The Supreme Court of the United States held that the Supreme Court of Louisiana had the power to issue a writ of error to the federal court. The Court reasoned that the writ of error was a part of the judicial power of the state, and that the state court had the right to issue it. The Court also held that the federal court was obligated to accept the writ of error and to proceed with the case. The Court concluded that the federal court had erred in refusing to accept the writ of error.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Gumbel v. Pitkin & Others, arguing that the majority's decision was incorrect and should be reversed. He argued that a state court had no jurisdiction to issue an injunction against a federal officer for acts done under color of his office as such officer, even if those acts were illegal or unconstitutional. According to Field, this principle was established by Marbury v Madison and could not be overruled by any other case or statute; it was part of the fundamental law of the United States which all courts must follow regardless of their own opinions on its correctness. Furthermore, he argued that Congress did not have authority to pass laws granting state courts jurisdiction over cases involving federal officers acting within their official capacity because doing so would violate Article III Section 2 Clause 1 of the Constitution which states "The judicial Power shall extend...to Controversies between two or more States." Thus, according to Justice Field's dissent in Gumbel v Pitkin & Others, Congress cannot grant state courts power over matters concerning federal officers acting within their official capacity and any attempt at doing so is unconstitutional.

Opinion written by Justice SFMiller
Decided: Mar 02, 1885
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