Sheldon v. Sill

Supreme Court of the United States
49 U.S. 441, 12 L. Ed. 1147 (1850)

ELI5:

Rule of Law:

Congress possesses the constitutional authority to define and limit the jurisdiction of the lower federal courts, and may withhold from them cognizance of any of the classes of cases enumerated in Article III of the Constitution.

Facts:

Sheldon, a citizen of Michigan, executed a bond and mortgage in favor of Hastings, who was also a citizen of Michigan.
Hastings was the President of the Bank of Michigan.
Subsequently, Hastings assigned the bond and mortgage to Sill, a citizen of New York.
Sill sought to recover the amount due on the bond and mortgage from Sheldon.

Procedural Posture:

Sill, a citizen of New York, filed a bill in the Circuit Court of the United States for the District of Michigan against Sheldon, a citizen of Michigan.
In his answer, Sheldon pleaded that the Circuit Court lacked jurisdiction under the Judiciary Act because the original parties to the bond and mortgage were both citizens of Michigan.
The case was heard by the Supreme Court of the United States on the question of the Circuit Court's jurisdiction.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the eleventh section of the Judiciary Act of 1789, which prohibits an assignee from suing in federal court based on diversity of citizenship if the original assignor could not have done so, unconstitutionally restrict the judicial power granted by Article III?

Opinions:

Majority - Mr. Justice Grier

No. The eleventh section of the Judiciary Act of 1789 is a constitutional exercise of Congress's power to define the jurisdiction of the lower federal courts. While Article III of the Constitution defines the outer limits of the federal judicial power, it does not self-execute or vest that power in any specific inferior court. Congress, possessing the power to 'ordain and establish' inferior courts, necessarily also has the power to prescribe and limit their jurisdiction. A statute limiting jurisdiction cannot conflict with the Constitution unless it confers powers not enumerated therein. The court further held that a suit on a bond and mortgage is a suit to recover the contents of a 'chose in action' within the meaning of the statute, because the debt is the principal matter and the mortgage is merely an incident to it. Therefore, since the assignor (Hastings) could not have sued the debtor (Sheldon) in federal court due to lack of diversity, the assignee (Sill) is also barred from doing so.

Analysis:

This case establishes the foundational principle that lower federal courts are courts of limited jurisdiction, defined by statute, not directly by the Constitution. It solidifies the doctrine that Article III serves as a ceiling, not a floor, for the subject-matter jurisdiction of these courts. This decision affirms Congress's supreme authority to control the jurisdiction of the federal judiciary, allowing it to manage the flow and types of cases heard. It prevents litigants from manufacturing diversity jurisdiction through the simple assignment of a claim to an out-of-state party, a principle that remains a cornerstone of federal jurisdiction law.

Gunnerbot

AI-powered case assistant

Loaded: Sheldon v. Sill (1850)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature