Stephen Johnson Field

This case involved a contract dispute in which Russ agreed to transfer to Telfener his claimed rights to purchase over a million acres of Texas public land under statutes requiring applications for surveys, filing of maps and field notes, and payment within set deadlines. Russ applied for surveys of 1,813 sections but did not complete proper on-the-ground surveys for the full tract, return all required documents to the General Land Office, or make the necessary payments, leaving the entire process incomplete. The Court held that no vested right or transferable interest in the lands passed to Russ solely from his application or partial efforts, as the state statutes created no binding obligation until all steps were fulfilled. It reversed the judgments below and remanded for a new trial because the incomplete compliance meant Russ had nothing to convey under the contract.

property

The case concerned a dispute over title to land in Washington Territory that had been reserved by Congress for university purposes under the act of July 17, 1854. One party traced its claim to a homestead entry made by Lemuel Holgate, while the other traced its claim to a conveyance by university commissioners to John Ross (later transferred to Brygger). The court held that Holgate's voluntary relinquishment of his homestead entry was valid and restored the land to the public domain, allowing the university commissioners' selection and conveyance to take effect under federal law and the practices of the land department. It therefore affirmed the judgment of the Supreme Court of Washington upholding title in the Brygger claimants.

propertyfederal power

This case was an ejectment action brought by plaintiff McHarry to recover possession of certain public land parcels in Contra Costa County, California, after defendant Stewart entered and claimed them. Stewart asserted a right to the land as an adjoining farm homestead under federal statutes (Rev. Stat. §§ 2289-2290), based on his ownership of adjacent property acquired from his wife, and he had initially received approval from the Commissioner of the General Land Office before the Secretary of the Interior reversed that decision on grounds that Stewart did not reside on the original farm. The Supreme Court of California affirmed a judgment for the plaintiff after sustaining a demurrer to Stewart's cross-complaint, and the U.S. Supreme Court affirmed that ruling. The Court held that Stewart's ownership satisfied the statutory requirements for an additional homestead entry, but the land department's factual finding regarding his lack of residence on the adjoining land was conclusive and not subject to judicial reexamination absent fraud or imposition. With these conclusions, the judgment in favor of the plaintiff was affirmed.

propertyfederal powerprocedure

This case was an equity suit filed in federal court by the New York heirs of Oliver Teall against numerous California residents, seeking to compel the transfer of extensive land holdings in San José based on allegations that Teall's attorney-in-fact, Davis Devine, fraudulently conveyed the property to himself via intermediary deeds executed around the time of Teall's 1857 death. The circuit court dismissed the claims, and the Supreme Court affirmed. The Court reasoned that Devine and his successors had exercised open, undisputed ownership and control of the property for decades without objection from Teall or his relatives, who never paid taxes or asserted any interest, giving rise to a presumption of valid title. It further held that California's statute of limitations for recovery of real property, combined with principles of adverse possession, barred any belated claims to disturb the long-settled ownership.

propertyprocedure

This case concerned a dispute over title to 110.80 acres of land in Sonoma County, California, between the heirs of John Mann, who had filed a preemption claim, and defendant Steiger, who claimed the land under the 1866 Act to quiet land titles as a purchaser from a Mexican grant. The U.S. Supreme Court affirmed the California Supreme Court's judgment for the defendant after a patent had been issued to him. The Court reasoned that the disputed land lay within the exterior boundaries of the confirmed Agua Caliente grant, which gave the defendant preferential rights under the 1866 Act over the preemption claim by Mann's heirs. Earlier decisions by land office officials had varied, but the final administrative ruling and patent favored the defendant based on the grant's boundaries as determined by survey and confirmation proceedings.

propertyfederal power

This case concerned a workplace injury at a mine where an inexperienced worker was severely harmed by an explosion of powder and caps stored in an engine-house with extreme heat from a boiler and ongoing jarring from operating machinery. The plaintiff sued the mine operators for negligence, alleging improper storage of explosives, failure to mitigate known risks like heat and vibration, and lack of any warning about the dangers. The jury found for the plaintiff, and the court affirmed the judgment, holding that employers in occupations with great and unusual dangers must use all readily attainable safety precautions known to science and inform workers of the hazards, with liability following from any negligence in these duties. The evidence showed the defendants were aware of the continuing risks yet took no steps to reduce them or warn the plaintiff, who had no prior knowledge or experience with explosives.

torts & liabilitylabor & employment

The case concerned an ejectment action brought in Montana territorial court by the successor in interest to purchasers at a sale of two mining claims, following default on bonds secured by a trust deed (or mortgage) executed by the Bell Silver and Copper Mining Company that included a power of sale. The Supreme Court of the Territory affirmed a district court judgment for the plaintiffs after a trial on stipulated facts, and the U.S. Supreme Court affirmed. The Court held that the power of sale contained in the indenture was valid and enforceable independently of any foreclosure proceeding; upon default and proper notice, the trustees could sell the property at public auction, and the resulting deed conveyed good title that extinguished the mortgagor's equity of redemption. The reasoning emphasized that such powers are routinely upheld in mortgages and deeds of trust, do not merge into or alter the character of the security instrument, and may be exercised according to their terms without violating Montana mortgage statutes.

propertybusiness & regulatory

The case involved a challenge by the Pittsburg & Southern Coal Co. to a Louisiana tax assessment and collection effort targeting coal that had been shipped from Pennsylvania and was being held in boats on the Mississippi River for sale. The company argued the coal was exempt as property in transit or in the process of transportation under state law and federal commerce principles. The Supreme Court affirmed the Louisiana Supreme Court's ruling that the tax collector could proceed, holding that the coal had arrived at its destination, was offered for sale, and had become part of the general mass of property in the state. The decision relied on the precedent in Brown v. Houston, concluding that the tax was a nondiscriminatory levy on property at rest rather than a burden on interstate commerce. The Court noted that states may tax such goods once they are no longer in transit, absent conflicting federal legislation.

taxesfederal powerbusiness & regulatory

The case concerned a challenge to a Louisiana statute establishing gaugers to measure the capacity of coal and coke boats and the weight of their cargo on the Mississippi River, brought by a company transporting coal from Pennsylvania. The Supreme Court upheld the law, concluding it did not conflict with Congress's power to regulate commerce, impose forbidden imposts or duties on imports or exports, violate conditions of Louisiana's admission to the Union, or discriminate against interstate shipments. The Court reasoned that the statute was a permissible police regulation for convenience in measurement that only indirectly affected commerce, that constitutional limits on imports and exports applied solely to foreign trade, and that the free navigation guarantee prohibited only direct burdens or unequal treatment of vessels rather than neutral measurement rules.

business & regulatoryfederal power

This case involved an appeal by the United States from a Circuit Court decree dismissing their bill in equity against the Illinois Central Railroad Company and others. The United States sought to prevent the railroad from taking possession of or diverting a parcel of land on the Lake Michigan shore in Chicago (part of the Fort Dearborn addition plat) that the United States had allegedly dedicated to public uses, claiming ownership and a right to enforce the dedication against private encroachment. After amendments removed claims related to the outer harbor, the Circuit Court sustained a demurrer to the remaining allegations. The Supreme Court affirmed the dismissal, holding that the United States lacked title to the land or standing to enforce any public easement or dedication against the defendants. The decision relied on prior rulings in related Lake Front litigation and principles that a dedicating party retains no enforceable interest once the dedication is made without retained rights.

propertyfederal power

The case concerned whether certain parcels of mineral land in Montana passed to the Northern Pacific Railroad Company under the federal land grant act of July 2, 1864, which authorized the railroad to select alternate sections along its proposed route but expressly excluded all mineral lands from the grant. The railroad sued for possession after identifying the sections upon definite location of its line, arguing that the lands were not known to be mineral at that time. The Supreme Court held that the mineral lands remained excluded and did not pass under the grant. The core reasoning was that the statutory language and an 1865 joint resolution made the exclusion of mineral lands absolute from the date of the grant, that the nature of the land was unaffected by the timing of its identification or knowledge of its mineral character, and that the grant attached only subject to that pre-existing exception.

propertyfederal powerbusiness & regulatory

The case Wharton v. Wise involved a Maryland citizen convicted in Virginia for illegally catching oysters in the Pocomoke River waters claimed by Virginia, who sought release via habeas corpus arguing rights under the 1785 Maryland-Virginia compact. The U.S. Supreme Court affirmed the lower court's denial of release, holding that the compact granted common fishing rights only in the Potomac River, not in the Pocomoke River or Sound, and that Virginia had jurisdiction to prosecute the offense against the state. The Court reasoned that the compact's provisions on fishing were limited to the Potomac, distinguished the Pocomoke as a separate body of water, and found that jurisdictional clauses for trials applied only to offenses against individual citizens, not state regulatory violations.

criminal lawpropertyprocedure

This case involved a dispute between co-owners of the Non-consolidated mining claim in Montana, where the plaintiff held a three-fourths interest and the defendant held one-fourth, over rights to a vein that originated in the defendant's solely owned Amy claim and extended into the Non-consolidated claim. The plaintiff sought partition of the Non-consolidated claim along with an accounting for ore extracted from the vein after it crossed the boundary. The Supreme Court reversed the lower court's judgment, holding that the Amy claim's owner had no rights to the vein once it passed the vertical plane of its north side line, which functioned as an end line rather than a side line under the applicable statute. The core reasoning rested on the interpretation of Revised Statutes section 2322, which limits extralateral rights to veins with apexes within a claim's surface lines but requires end lines to define the boundaries of such rights, preventing the court from reconfiguring the claim's boundaries to expand those rights.

propertyfederal power

The case concerned whether a federal circuit court had jurisdiction under an 1885 act of Congress to try an offense committed on the La Court Oreilles Indian reservation in Wisconsin. The reservation was formed from lands ceded by the Chippewa Indians in 1842 and 1854 treaties that preserved the tribes' rights of occupancy, which had never been terminated by presidential order. The Supreme Court held that the federal court possessed jurisdiction because the enabling act granting Wisconsin school sections was subordinate to those prior Indian occupancy rights, and because Congress has authority to legislate for the protection of Indians on reservations as wards of the United States. The Court relied on the precedent in United States v. Kagama recognizing federal power over criminal acts by or against Indians within reservation boundaries, even when located inside a state. It therefore answered the certified question in the affirmative and directed denial of the motion to set aside the verdict.

criminal lawfederal powerproperty

The case concerned whether section 5346 of the Revised Statutes, which criminalized certain acts committed on the 'high seas,' extended federal jurisdiction to offenses on the open waters of the Great Lakes, specifically the Detroit River between the United States and Canada. The Supreme Court held that the term 'high seas' applied to the unenclosed waters of the Great Lakes, allowing the federal courts to exercise admiralty jurisdiction over crimes committed there outside any state's jurisdiction. The Court reasoned that 'high seas' historically referred to open waters beyond narrow headlands or county boundaries on any sea or ocean free to navigation, not solely the Atlantic or Pacific, and that the Great Lakes qualified as such bodies of water given their size, commerce, and connection via the St. Lawrence River. A separate opinion disagreed, contending that Congress intended the term to cover only waters directly linked to the ocean and that exclusive jurisdiction lay with Canadian authorities where the crime occurred.

criminal lawfederal power

The case concerned a dispute over title to land in California that had been patented by the federal government to a railroad company under an 1862 Congressional grant but was also claimed by a defendant under a preemption right; the land fell within the exterior boundaries of a Mexican grant whose validity was then under federal review. The U.S. Supreme Court held that the railroad's patent was valid and not void, reversing the California Supreme Court, because only the specific quantity confirmed in the Mexican grant (two square leagues) was reserved from sale or disposition, not the entire area described by the exterior boundaries. The Court reasoned from prior precedent, including United States v. McLaughlin, that when a Mexican grant covered a fixed quantity within larger boundaries, the government remained free to grant the surplus as public land once sufficient area was set aside to satisfy the confirmed quantity. Because the railroad's patented land lay outside the actual surveyed two-league tract, the patent conveyed good title and defeated the preemption claim.

propertyfederal power

The case involved the Minneapolis and St. Louis Railway Company as plaintiff in error against Nelson. The Supreme Court noted that the facts were similar to those in a previously decided case, and by stipulation, the matter was to be handled identically. The Court affirmed the judgment accordingly.

business & regulatoryprocedure

This case involved a Minnesota farmer who sued a railroad company for failing to construct required fences and cattle guards along its tracks through his property, as mandated by state law. The farmer sought damages for expenses incurred in watching his cattle to prevent them from being hit by trains, along with loss of land use and diminished property value. The U.S. Supreme Court affirmed the lower court's judgment in favor of the farmer, holding that the state statute was a valid exercise of the police power to regulate railroads for the protection of adjacent property and public safety. The Court rejected arguments that the law violated the Equal Protection Clause, Due Process Clause, or the company's charter rights, reasoning that states have broad discretion to impose duties and penalties on railroads to minimize harm to neighboring lands.

business & regulatorypropertytorts & liability

This case involved a criminal defendant convicted after the prosecutor commented during closing arguments on the defendant's failure to testify in his own behalf, suggesting it indicated guilt. The Supreme Court reversed the conviction and ordered a new trial. The core reasoning was that a federal statute explicitly prohibits any presumption against a defendant for not requesting to be a witness and bars comments that would create such a presumption, and the prosecutor's remarks, combined with the trial court's insufficient response, violated this protection by undermining the presumption of innocence.

criminal lawprocedure

The case concerned a dispute between Virginia and Tennessee over the correct boundary line separating the two states. Virginia argued that the boundary should follow the 36°30' north latitude as per historical charters, while Tennessee maintained that a line established by joint commissioners in 1802-1803 and ratified by both states' legislatures in 1803 had been the accepted boundary for over 85 years. The Supreme Court held that the 1803 compact line constitutes the true boundary between the states. The court's reasoning emphasized the long-standing agreement, legislative approval, and mutual acquiescence, which established the line as binding regardless of minor deviations from the chartered latitude.

federal powerproperty