Deference to government powerSkepticism of government power
Commerce Clause cases enforce federal supremacy to invalidate state barriers while permitting only those state actions that do not conflict with congressional design. Smith v. Alabama ↗ Bowman v. Chicago & Northwestern… ↗
Judicial activismJudicial restraint
Court consistently confines itself to applying enacted statutes and established precedents to the facts found below rather than expanding or reshaping remedies. Hoboken v. Pennsylvania Railroad ↗ Stuart v. Gay ↗
This case concerned the enforcement of a prior judicial decree ordering the sale of real property, where the purchaser William A. Stuart had conveyed title pendente lite to the White Sulphur Springs Company while leaving part of the purchase money unpaid and secured by a reserved lien. The lower court issued a decree for resale via a rule to show cause after Stuart attempted to claim credits against the purchase bonds based on liens he held, leading to disputes over the calculation of interest and amounts due. The Supreme Court affirmed, holding that the summary procedure was proper because the cause remained open with the court retaining control over title, no rights of innocent third parties had intervened, and Stuart had full opportunity to present his defenses. The Court further reasoned that the master's report confirmed in 1876, along with subsequent decrees, fixed the debts as principal plus interest to October 15, 1875, making that aggregate the new principal from which further interest properly accrued without improper compounding.
The case involved a dispute over whether a supplemental bill filed by the International Bank in a foreclosure proceeding against property of bankrupt Walker was barred by the two-year statute of limitations in Section 5057 of the Revised Statutes, which applies to suits between a bankruptcy assignee and parties claiming adverse interests in property. The assignee argued that the supplemental bill, filed more than two years after the assignee took title and relying on a decree from a related Wilshire suit, constituted a new cause of action. The court held that the supplemental bill did not start a new suit or assert a distinct claim but instead introduced new matter arising after the original bill to support the existing foreclosure relief, functioning as evidence of the amount due via res judicata rather than merging or replacing the original cause of action. Because the statute of limitations did not apply, the Supreme Court of Illinois was affirmed on the sole federal question presented.
This case involved a dispute over whether a bank that held bonds secured by a deed of trust on real estate, pledged as collateral for a loan to Bowen Brothers, properly acquired title to the property through a series of sales following default and bankruptcy. The complainant, successor to the original debtors, sought an accounting from the bank for proceeds from the sale of the land, arguing that the bank held the property in trust and could not purchase it for its own benefit. The Supreme Court affirmed the lower court's decision against the complainant, holding that the principles applicable to pledges do not extend to real estate conveyed to a third-party trustee under a deed of trust, allowing the creditor to bid at the trustee's sale. The Court reasoned that the trustee's sale was valid and conducted properly, and that any interest from the bankruptcy proceedings had already been conveyed to another party, extinguishing the complainant's claims.
This case involved a taxpayer who paid disputed state and county taxes under protest to the Charleston County Treasurer and then sued under a South Carolina statute to recover the amounts, seeking a judicial declaration that the taxes were illegally collected. The South Carolina Supreme Court ruled that the plaintiff did not qualify for the statutory remedy. The U.S. Supreme Court dismissed the writ of error for lack of jurisdiction, holding that the state court's judgment rested on independent state-law grounds interpreting the statute's scope rather than on any federal constitutional question. The opinion emphasized that federal jurisdiction requires an actually decided federal issue necessary to the outcome, which was absent here.
The case concerned the interpretation of David D. Colton's will, which bequeathed his entire estate to his widow Ellen M. Colton while recommending that she care for and provide for his mother and sister. The court held that the widow took the estate subject to a trust enforceable in equity for the benefit of the mother and sister, entitling them to a suitable lifetime provision from the estate. The reasoning was that the will's language expressed an intention to create a trust, and although the manner of execution was left to the widow's discretion, a court of equity could intervene to ensure a proper and honest exercise of that discretion, particularly where the trustee failed to act appropriately. There was no prior final adjudication by the probate court that would bar the claims.
The case involved claims by freighting companies for losses to their livestock and operations when US troops detained their wagon trains en route to Salt Lake City in 1857, preventing delivery of goods to Mormon settlements amid tensions with the federal government. Congress referred the claims to the Court of Claims, which awarded judgments for the plaintiffs. On appeal, the Supreme Court held that while the referring act permitted adjudication, the awards improperly included consequential damages beyond the scope of property actually taken or impressed into service, and the findings lacked specificity on the allowable claims. Therefore, the Court reversed the judgments and remanded for further proceedings and more precise findings.