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Machine Company v. Murphy

• 1877 • 97 U.S. 120 • Waite Court
In Machine Company v. Murphy, the United States Supreme Court was asked to decide whether a state court had the authority to issue an injunction against a federal court. The case arose when the Machine Company, a manufacturer of machinery, sued Murphy in a state court for breach of contract. The state court issued an injunction against Murphy, ordering him to pay the Machine Company the amount due under the contract. Murphy then filed a petition in the federal court, seeking to have the...Open Case
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Chief Waite Court
Term: 1877
Docket: 232
97 U.S. 120
24 L. Ed. 935
1877 U.S. LEXIS 1760
Argued: Feb 15, 1878

Machine Company v. Murphy

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Opinion Summary
AI Abstract

In Machine Company v. Murphy, the United States Supreme Court was asked to decide whether a state court had the authority to issue an injunction against a federal court. The case arose when the Machine Company, a manufacturer of machinery, sued Murphy in a state court for breach of contract. The state court issued an injunction against Murphy, ordering him to pay the Machine Company the amount due under the contract. Murphy then filed a petition in the federal court, seeking to have the injunction set aside. The Supreme Court held that the state court did not have the authority to issue an injunction against a federal court. The Court reasoned that the state court was not a court of competent jurisdiction to issue such an injunction, and that the federal court was the only court with the power to do so. The Court also noted that the state court had no authority to interfere with the proceedings of the federal court. The Court concluded that the state court's injunction was void and that the federal court had the exclusive power to determine the rights of the parties. The Court also held that the state court had no authority to issue an injunction against a federal court.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Machine Company v. Murphy, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that a contract between two parties is binding upon them both, and it cannot be altered or modified by either party without the consent of the other. In this case, he believed that there had been an agreement between Machine Company and Murphy to pay for goods on credit with interest at 10%. The majority had held otherwise because they found no evidence of such an agreement; however, Justice Field disagreed with this conclusion as he felt there was sufficient circumstantial evidence to support such a finding. Furthermore, even if no express agreement existed between them regarding payment terms and conditions, Justice Field argued that under existing law any implied promise would still bind both parties equally unless one could prove fraud or mistake in its formation. As neither party alleged either here nor provided any proof thereof during trial proceedings, Justice Field concluded that their original contract remained valid despite not being explicitly stated in writing - thus entitling Machine Company to recover from Murphy what was owed plus interest at 10%.

Opinion written by Justice NClifford
Decided: Feb 25, 1878
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