Minneapolis & St. Louis Railroad v. Bombolis
1916 U.S. LEXIS 1744, 241 U.S. 211, 36 S. Ct. 595 (1916)
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Rule of Law:
The Seventh Amendment's requirement of a unanimous jury verdict in civil cases is a procedural rule that applies only to trials in federal courts and does not bind state courts, even when they are adjudicating a cause of action created by federal law.
Facts:
- Nanos, an employee of the Minneapolis & St. Louis Railroad Co., was engaged in interstate commerce at the time of his death.
- Nanos's death was alleged to have been caused by the negligence of the railroad company.
- The administrator of Nanos's estate sued the railroad under the Federal Employers’ Liability Act (FELA), a federal law.
- The case was tried before a jury in a Minnesota state court.
- Minnesota's state constitution and laws permitted a civil jury to reach a valid verdict with the agreement of only five-sixths of its members after twelve hours of deliberation.
Procedural Posture:
- The administrator of Nanos's estate sued the Minneapolis & St. Louis Railroad Co. in a Minnesota state trial court under the Federal Employers' Liability Act.
- At trial, the railroad objected to the court's jury instruction, based on Minnesota law, that a non-unanimous verdict (five-sixths) was permissible.
- The trial court overruled the objection, and the jury returned a verdict for the plaintiff.
- The railroad company, as appellant, appealed to the Supreme Court of Minnesota, the state's highest court.
- The Supreme Court of Minnesota affirmed the trial court's judgment, holding the Seventh Amendment inapplicable to state court proceedings.
- The railroad company sought and was granted a writ of error from the Supreme Court of the United States.
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Issue:
Does the Seventh Amendment's guarantee of a trial by jury, which requires a unanimous verdict, apply to a civil case brought in a state court under a federal statute, thereby invalidating a state law that permits a non-unanimous verdict?
Opinions:
Majority - Chief Justice White
No. The Seventh Amendment does not apply to state court proceedings. It is a long and conclusively settled principle that the first ten Amendments to the Constitution, including the Seventh, are limitations on the federal government and not on the states. Therefore, the Seventh Amendment applies only to proceedings in federal courts and does not govern trials by jury in state courts or the standards they must apply. The fact that the right being enforced is a federal one (created by the Federal Employers' Liability Act) does not transform the state court into a federal court or subject its procedures to the Seventh Amendment. State courts may apply their own neutral procedural rules when adjudicating federal claims, as our dual system of government presumes concurrent jurisdiction where state and federal courts can enforce rights regardless of their origin, each using its own established modes of procedure.
Analysis:
This decision firmly establishes that the procedural requirements of the Bill of Rights, specifically the Seventh Amendment's jury trial provision, are not binding on state courts. It reinforces the principle of dual sovereignty, clarifying that while state courts may be obligated to enforce federal law, they do so as independent judicial bodies using their own procedures. This case prevents the federalization of state court procedure whenever a federal cause of action is litigated, maintaining a crucial distinction between the procedural rules of the state and federal judicial systems. It stands for the proposition that the source of the law creating the right does not dictate the procedural rules of the forum adjudicating that right.
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