New York v. Connecticut

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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; 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, because 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 by: Ellsworth
Joined by: Paterson, Chase, Washington
Cushing and Iredell took no part in the consideration or decision of the case.

New York v. Connecticut, 4 U.S. 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. It 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.

Contents

[edit] Background of the case

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.[1]

After the State of 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; only state or federal courts in New York could accordingly exercise jurisdiction over the action. The plaintiffs claimed that the lands were instead in Connecticut.

The Supreme Court denied a motion to remove the cases from the Circuit Court,[2] and New York subsequently filed a bill in equity against Connecticut and the Connecticut plaintiffs for an injunction to stay the ejectment proceedings.[3] 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.

Because the bill in equity was filed while the Connecticut General Assembly was out of session,[4] 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 regardless, New York lacked an interest in the proceedings to merit a stay.

[edit] The Court's decision

The Court found that notice was sufficient, because 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, finding that New York lacked standing. It was not a party to the suits in the lower court, nor did it have a concrete interest in the decisions. The State was claiming jurisdiction over the land, not title to it, and the Circuit Court lacked the power to determine the State's boundaries and its consequent rights.

[edit] See also

[edit] Notes

  1. ^ This building is now known as the Old State House.
  2. ^ See Fowler v. Lindsey, 3 U.S. (Dall.) 411 (1799).
  3. ^ The bill was filed by Josiah Ogden Hoffman, the Attorney General of New York.
  4. ^ According to the defendants' counsel, the General Assembly had not met since the Supreme Court denied the motion to remove in Fowler.

[edit] References

[edit] Further reading

  • The Connecticut Gore Title, Stated and Considered, Showing The Right of the Proprietors, to the Lands Lately Purchased by Them, from the State of Connecticut: Lying West of the Delaware River. Hudson & Goodwin (Hartford, 1799). An advocacy for Connecticut's right to the land, which contains the text of eighteen original documents pertaining to the land dispute dating back to 1631.
  • The Rise, programs, and effect of the claim of the proprietors of the Connecticut Gore, stated and considered. Hudson & Goodwin (Hartford, 1802).