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In White v. Crow & Others, 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 compel a county court to issue a deed to a party who had purchased land at a tax sale. The Supreme Court held that the state court did not have the authority to issue the writ of mandamus. The case arose when the plaintiff, White, purchased land at a tax sale in the state of Arkansas. The county court refused to issue a deed to White, and White sought relief from the state court. The state court issued a writ of mandamus to the county court, ordering it to issue the deed. The county court refused to comply with the writ, and the state court held the county court in contempt. The Supreme Court held that the state court did not have the authority to issue the writ of mandamus. The Court reasoned that the writ of mandamus was a remedy of last resort, and that the state court should have allowed the county court to exercise its discretion in deciding whether to issue the deed. The Court also held that the state court did not have the authority to hold the county court in contempt. The Supreme Court's decision in White v. Crow & Others established that state courts do not have the authority to issue writs of mandamus to compel county courts to issue deeds. The decision also established that state courts do not have the authority to hold county courts in contempt.
Justice Field delivered the dissenting opinion in White v. Crow & Others, arguing that the majority's decision was wrongfully based on a misinterpretation of an 1867 treaty between the United States and several Native American tribes. He argued that while it is true that under this treaty, certain lands were set aside for tribal members to use as hunting grounds, this did not mean they had exclusive rights to these lands or could prevent non-tribal members from using them. Rather, he argued that all citizens should be allowed access to public land regardless of race or ethnicity. Furthermore, Justice Field noted how allowing only tribal members access would create two classes of citizens with unequal rights - something which goes against fundamental principles of justice and equality enshrined in our Constitution. In conclusion, Justice Field believed granting exclusive rights over public land solely to one group violated both federal law and basic constitutional principles; therefore he dissented from the majority opinion in White v. Crow & Others