New York v. Connecticut

New York v. Connecticut
New York v. Connecticut
	Supreme Court of the United States
Original jurisdiction; Decided August 9, 1799
Full case name	The State of New-York v. The State of Connecticut, et al.
Citations	4 U.S. 1 ( more ) 4 Dall. 1; 1 L. Ed. 715; 1799 U.S. LEXIS 243
Claim	New York moved to enjoin ejectment proceedings pending in a U.S. Circuit Court involving land over which New York and Connecticut claimed jurisdiction.
Procedural history	Injunction denied, 4 U.S. 1 (1799) (Ellsworth, C.J.)
Outcome
	The State of New York was not a party to the ejectment action and had no interest at stake since the Circuit Court lacked the power to determine its claim of rights over the disputed lands. Injunction denied.
Court membership
	Chief Justice Oliver Ellsworth Associate Justices William Cushing · James Iredell ; William Paterson · Samuel Chase ; Bushrod Washington
Case opinions
Majority	Ellsworth, joined by Paterson, Chase, Washington
	Cushing and Iredell took no part in the consideration or decision of the case.

Last updated April 27, 2019

New York v. Connecticut, 4 U.S. (4 Dall.) 1 (1799), was a lawsuit heard by the Supreme Court of the United States between the State of New York against the State of Connecticut in 1799 that arose from a land dispute between private parties. The case was the first case in which the Supreme Court exercised its original jurisdiction under Article III of the United States Constitution to hear controversies between two states.

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.

New York is a state in the Northeastern United States. New York was one of the original thirteen colonies that formed the United States. With an estimated 19.54 million residents in 2018, it is the fourth most populous state. In order to distinguish the state from the city with the same name, it is sometimes referred to as New York State.

Connecticut is the southernmost state in the New England region of the United States. As of the 2010 Census, it has the highest per-capita income, Human Development Index (0.962), and median household income in the United States. It is bordered by Rhode Island to the east, Massachusetts to the north, New York to the west, and Long Island Sound to the south. Its capital is Hartford and its most populous city is Bridgeport. It is part of New England, although portions of it are often grouped with New York and New Jersey as the Tri-state area. The state is named for the Connecticut River which approximately bisects the state. The word "Connecticut" is derived from various anglicized spellings of an Algonquian word for "long tidal river".

Background

The Connecticut Gore region was a strip of land on New York's western border with Pennsylvania. Connecticut claimed jurisdiction over the land and granted it to Jeremiah Halsey and Andrew Ward in exchange for their construction of the state house in Hartford. (The building is now known as the Old State House.)

Pennsylvania, officially the Commonwealth of Pennsylvania, is a state located in the northeastern, Great Lakes and Mid-Atlantic regions of the United States. The Appalachian Mountains run through its middle. The Commonwealth is bordered by Delaware to the southeast, Maryland to the south, West Virginia to the southwest, Ohio to the west, Lake Erie and the Canadian province of Ontario to the northwest, New York to the north, and New Jersey to the east.

A land grant is a grant of land – held by a government to hold until the land it granted to a person. The United States historically gave out numerous land grants to people desiring farmland. The American Industrial Revolution was guided by many supportive acts of legislatures promoting commerce or transportation infrastructure development by private companies, such as the Cumberland Road turnpike, the Lehigh Canal, the Schuylkill Canal, and the many railroads that tied the young United States together.

Hartford is the capital city of Connecticut. It was the seat of Hartford County until Connecticut disbanded county government in 1960. The city is nicknamed the "Insurance Capital of the World", as it hosts many insurance company headquarters and is the region's major industry. It is the core city in the Greater Hartford area of Connecticut. Census estimates since the 2010 United States Census have indicated that Hartford is the fourth-largest city in Connecticut, behind the coastal cities of Bridgeport, New Haven, and Stamford.

After New York granted certain parcels within the Connecticut Gore to other individuals, the successors in title to Halsey and Ward filed an action for ejectment in the United States Circuit Court for the District of Connecticut. The defendants argued that they were residents of New York and that the land was actually in Steuben County, New York and so only state or federal courts in New York could exercise jurisdiction over the action. The plaintiffs claimed that the lands were actually in Connecticut.

In property law, a title is a bundle of rights in a piece of property in which a party may own either a legal interest or equitable interest. The rights in the bundle may be separated and held by different parties. It may also refer to a formal document, such as a deed, that serves as evidence of ownership. Conveyance of the document may be required in order to transfer ownership in the property to another person. Title is distinct from possession, a right that often accompanies ownership but is not necessarily sufficient to prove it. In many cases, possession and title may each be transferred independently of the other. For real property, land registration and recording provide public notice of ownership information.

Ejectment is a common law term for civil action to recover the possession of or title to land. It replaced the old real actions and the various possessory assizes where boundary disputes often featured. Though still used in some places, the term is now obsolete in many common law jurisdictions, in which possession and title are sued by the actions of eviction and quiet title, respectively.

The United States circuit courts were the original intermediate level courts of the United States federal court system. They were established by the Judiciary Act of 1789. They had trial court jurisdiction over civil suits of diversity jurisdiction and major federal crimes. They also had appellate jurisdiction over the United States district courts. The Judiciary Act of 1891 transferred their appellate jurisdiction to the newly created United States circuit courts of appeals, which are now known as the United States courts of appeals. On January 1, 1912, the effective date of the Judicial Code of 1911, the circuit courts were abolished, with their remaining trial court jurisdiction transferred to the U.S. district courts.

The Supreme Court denied a motion to remove the cases from the Circuit Court,^[1] and New York subsequently filed a bill in equity against Connecticut and the Connecticut plaintiffs for an injunction to stay the ejectment proceedings.^[2] As part of the bill, New York submitted an agreement between the states, dated November 28, 1683, that purported to recognize New York's rights to the land.

In United States law, a motion is a procedural device to bring a limited, contested issue before a court for decision. It is a request to the judge to make a decision about the case. Motions may be made at any point in administrative, criminal or civil proceedings, although that right is regulated by court rules which vary from place to place. The party requesting the motion may be called the movant, or may simply be the moving party. The party opposing the motion is the nonmovant or nonmoving party.

In the United States, removal jurisdiction sometimes exists for the defendant to move a civil action filed in a state court to the United States district court in the district in which the state court is located. A federal statute, 28 U.S.C. § 1441et seq., governs removal.

In jurisdictions following the English common law system, equity is the body of law which was developed in the English Court of Chancery and which is now administered concurrently with the common law.

Because the bill in equity was filed while the Connecticut General Assembly was out of session,^[3] the state never actually participated in the case. However, attorneys for the private land claimants argued that reasonable notice was not given for the injunction to be granted and that New York also lacked an interest in the proceedings to merit a stay.

The Connecticut General Assembly (CGA) is the state legislature of the U.S. state of Connecticut. It is a bicameral body composed of the 151-member House of Representatives and the 36-member Senate. It meets in the state capital, Hartford. There are no term limits for either chamber.

Notice is the legal concept describing a requirement that a party be aware of legal process affecting their rights, obligations or duties. There are several types of notice: public notice, actual notice, constructive notice, and implied notice.

Decision

The Court found that notice was sufficient since a shorter period of time may be reasonable when the application for injunction is made to a court, rather than a single judge. However, the Court denied the injunction and found that New York lacked standing. It had not been a party to the suits in the lower court and had no concrete interest in the decisions. Also, it was claiming jurisdiction over the land, not title to it. The Circuit Court lacked the power to determine either its boundaries or its consequent rights.

In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case. Standing exists from one of three causes:

The party is directly subject to an adverse effect by the statute or action in question, and the harm suffered will continue unless the court grants relief in the form of damages or a finding that the law either does not apply to the party or that the law is void or can be nullified. This is called the "something to lose" doctrine, in which the party has standing because they will be directly harmed by the conditions for which they are asking the court for relief.
The party is not directly harmed by the conditions by which they are petitioning the court for relief but asks for it because the harm involved has some reasonable relation to their situation, and the continued existence of the harm may affect others who might not be able to ask a court for relief. In the United States, this is the grounds for asking for a law to be struck down as violating the First Amendment to the Constitution of the United States, because while the plaintiff might not be directly affected, the law might so adversely affect others that one might never know what was not done or created by those who fear they would become subject to the law – the so-called "chilling effects" doctrine.
The party is granted automatic standing by act of law. Under some environmental laws in the United States, a party may sue someone causing pollution to certain waterways without a federal permit, even if the party suing is not harmed by the pollution being generated. The law allows them to receive attorney's fees if they substantially prevail in the action. In some U.S. states, a person who believes a book, film or other work of art is obscene may sue in their own name to have the work banned directly without having to ask a District Attorney to do so.

Notes

↑ See Fowler v. Lindsey , 3 U.S. (Dall.) 411 (1799).
↑ The bill was filed by Josiah Ogden Hoffman, the Attorney General of New York.
↑ According to the defendants' counsel, the General Assembly had not met since the Supreme Court denied the motion to remove in Fowler.

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References

Full text of the Court's decision at Wikisource

External links

Text of New York v. Connecticut, 4 U.S. (4 Dall. )1(1799) is available from: Justia Library of Congress OpenJurist

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[1] See Fowler v. Lindsey , 3 U.S. (Dall.) 411 (1799).

[2] The bill was filed by Josiah Ogden Hoffman, the Attorney General of New York.

[3] According to the defendants' counsel, the General Assembly had not met since the Supreme Court denied the motion to remove in Fowler.