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In Martin, Sheriff, & Others v. Webb & Others, Trustees, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue a writ of mandamus to a county sheriff. The case arose out of a dispute between the trustees of a school district and the county sheriff of Washington County, Arkansas. The trustees had requested that the sheriff levy a tax to fund the school district, but the sheriff refused to do so. The trustees then sought a writ of mandamus from the state court, which the sheriff contested. The Supreme Court held that the state court had the authority to issue the writ of mandamus. The Court reasoned that the state court had the power to issue the writ because the sheriff was a public officer and the trustees were seeking to enforce a public right. The Court also noted that the writ of mandamus was a proper remedy for the trustees to seek in order to compel the sheriff to perform his duty. The Court thus affirmed the decision of the state court.
In Martin, Sheriff, & Others v. Webb & Others, Trustees (1884), the Supreme Court was asked to decide whether a state court had jurisdiction over land located in another state. The majority opinion held that the state court did not have jurisdiction and thus could not issue an injunction against the defendants who were trustees of certain lands located in Mississippi but owned by citizens of Georgia. Justice Field dissented from this decision on two grounds: firstly, he argued that it was within the power of Congress to grant exclusive jurisdiction over such matters; secondly, he contended that even if Congress had not granted such authority to federal courts they should still be able to exercise concurrent jurisdiction with respect to cases involving property situated across multiple states as long as there is no conflict between laws applicable in each respective state. In conclusion, Justice Field believed that since there was no dispute regarding which law applied here - both Georgia and Mississippi recognized title by adverse possession - then it would be appropriate for either a federal or a state court with proper jurisdictional authority to hear this case and issue an injunction accordingly.