Louisiana v. Jumel
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| Louisiana v. Jumel | |
| Reference: 107 U.S. 711 | |
| Term: 1883 | |
| Important Dates | |
| Argued: N/A Decided: March 5, 1883 | |
| Outcome | |
| United States Circuit Court for the Eastern District of Louisiana affirmed | |
| Majority | |
| Morrison Waite | |
| Dissenting | |
| Stephen Johnson Field • John Harlan I | |
Louisiana v. Jumel is a case decided on March 5, 1883, by the United States Supreme Court holding that lawsuits against state officials are equivalent to lawsuits against states and are therefore unconstitutional. The case concerned a suit against several state officials of Louisiana for unpaid consolidated bonds. The Supreme Court affirmed the decision of the United States Circuit Court for the Eastern District of Louisiana.[1]
Why it matters: The Supreme Court's decision in this case established that lawsuits against state officials were equivalent to lawsuits against states, which are barred by the Eleventh Amendment. To read more about the impact of Louisiana v. Jumel click here.
Background
The Louisiana state legislature enacted a statute in 1874 to issue consolidated bonds with the aim of reducing debt. The bonds were to be made payable for 40 years from January 1, 1874, with seven percent interest paid annually, not to exceed a total of $15,000,000. On January 1, 1880, a new state constitution was established that stated the following:
| “ | Be it ordained by the people of the state of Louisiana, in convention assembled, that the interest to be paid on the consolidated bonds of the state of Louisiana be and is hereby fixed at 2 per cent. per annum for 5 years from the first day of January, 1880, 3 per cent. per annum for 15 years, and and 4 per cent. per annum thereafter, payable semi-annually; and there shall be levied an annual tax sufficient for the full payment of said interest, not exceeding three mills, the limit of all state tax being hereby fixed at six mills: provided, the holders of consolidated bonds may, at their option, demand, in exchange for the bonds held by them, bonds of the denomination of five dollars, one hundred dollars, five hundred dollars, one thousand dollars, to be issued at the rate of 75 cents on the dollar of bonds held, and to be surrendered by such holders; the said new issue to bear interest at the rate of 4 per cent. per annum, payable semi-annually. [3] | ” |
The bondholders, John Elliot, Nicholas Gwynn, and Henry S. Walker, requested the payment due January 1, 1880, but the state auditor and treasurer refused. The bondholders filed a lawsuit against state officials in the United States Circuit Court for the Eastern District of Louisiana, including the state auditor, treasurer, governor, lieutenant governor, secretary of state, speaker of the House of Representatives, a fiscal agent for the State National Bank of New Orleans, and several members of the board of liquidation. The circuit court held that the state officials were not obligated to pay or collect the funds and were protected from doing so because they were officers of the state.[2]
Oral argument
The date of oral argument is unknown. The case was decided on March 5, 1883.[1]
Decision
The Supreme Court decided 7-2 to affirm the decision of the United States Circuit Court for the Eastern District of Louisiana. Chief Justice Morrison Waite delivered the opinion of the court. Justices Stephen Johnson Field and John Harlan I wrote dissenting opinions.[1]
Opinions
Opinion of the court
Chief Justice Morrison Waite, writing for the court, argued that the state officials were under no obligation to the bondholders because they were officers of the state and were acting as the state had directed them. Waite contended that because of that fact, the state officials could not be sued by the bondholders.[2]
| “ | The treasurer of the state is the keeper of the treasury, and in that way is the keeper of the money collected from this tax just as he is the keeper of other public moneys. The taxes were collected by the tax-collectors and paid over to the state treasurer,- that is to say, into the state treasury,-just as other taxes were when collected. The treasurer is no more a trustee of these moneys than he is of all other public moneys. He holds them, but only as the agent of the state. If there is any trust, the state is the trustee, and unless the state can be sued the trustee cannot be enjoined. The officers owe duty to the state alone, and have no contract relations with the bondholders. They can only act as the state directs them to act, and hold as the state allows them to hold. It was never agreed that their relations with the bondholders should be any other than as officers of the state, or that they should have any control over this fund except to keep it like other funds in the treasury and pay it out according to law. They can be moved through the state, but not the state through them. [3] | ” |
| —Morrison Waite, majority opinion in Louisiana v. Jumel[2] | ||
Waite also posited that the courts did not have the authority or jurisdiction to carry out lawsuits against states or their officials, and therefore affirmed the lower court's decision to dismiss the case for mandamus.[2]
| “ | The remedy sought, in order to be complete, would require the court to assume all the executive authority of the state, so far as it related to the enforcement of this law, and to supervise the conduct of all persons charged with any official duty in respect to the levy, collection, and disbursement of the tax in question until the bonds, principal and interest, were paid in full, and that, too, in a proceeding to which the state, as a state, was not and could not be made a party. It needs no argument to show that the political power cannot be thus ousted of its jurisdictian, and the judiciary set in its place. When a state submits itself, without reservation, to the jurisdiction of a court in a particular case, that jurisdiction may be used to give full effect to what the state has by its act of submission allowed to be done; and if the law permits coercion of the public officers to enforce any judgment that may be rendered, then such coercion may be employed for that purpose. But this is very far from authorizing the courts, when a state cannot be sued, to set up its jurisdiction over the officers in charge of the public moneys, so as to control them as against the political power in their administration of the finances of the state. In our opinion to grant the relief asked for in either of these cases would be to exercise such a power. [3] | ” |
| —Morrison Waite, majority opinion in Louisiana v. Jumel[2] | ||
Dissenting opinions
Justice Stephen Johnson Field, in a dissenting opinion, argued that the state of Louisiana was obligated to pay the interest owed to the bondholders. Field contended that the 1874 act that established the consolidated bonds was binding, and therefore must be adhered to by the state officials. He argued that the enactment of new constitutional statutes should be void and the original terms of the act should be upheld.[2]
| “ | If the new constitution had never been adopted there could be no question as to the power of the state courts to require that the moneys collected be applied to the payment of the interest. It would not only have been the duty of the board of liquidation to thus apply them, but it would have been a felony to refuse to do so. Now, whatever enactment, constitutional or legislative, impairs the obligation of the contract with the bondholders-that is, abrogates or lessens the means of its enforcement- is void. Therefore, the new constitution, as to that contract, is to be treated as though it never existed. [3] | ” |
| —Stephen Johnson Field, dissenting opinion in Louisiana v. Jumel[2] | ||
Justice John Harlan I, in a dissenting opinion, argued that the majority opinion of the court did not align with precedent that had been previously established by the Supreme Court. Harlan posited that the contract between the state of Louisiana and the bondholders was binding and must be upheld. He also argued that the Eleventh Amendment should not be construed to prohibit lawsuits against state officials.[1]
| “ | This language needs no interpretation. While the federal constitution declares that it shall be the supreme law of the land, anything in the constitution of any state to the contrary notwithstanding, the supreme court of Louisiana holds that, in the matter of state contracts, her constitution is the exclusive mandate to, and absolutely binding upon, her officers, anything in the constitution of the United States to the contrary notwithstanding. And I take leave to say, with all respect for my brethren, that the decision this day rendered can be sustained upon no other ground. But in vain has this court repeatedly adjudged that a suit against the officers of a state or enforce the performance of plain official duties is not necessarily one against the state, within the meaning of that constitution; in vain has it often decided that contracts with states are as fully protected by that constitution as are those between individuals, and that a state can no more impair an existing contract by constitutional provision than by a legislative act; in vain have the circuit courts of the United States been invested with jurisdiction of all suits arising under the constitution and laws of the United States; in vain does that constitution declare that it shall be the supreme law of the land, binding upon the judges in every state, if it be true, as determined by the supreme court of Louisiana, that no court can ever have power to decree a provision of a state constitution invalid on the ground that it impairs the obligation of contracts with that state, or to compel state officers to disregard such invalid provision. [3] | ” |
| —John Harlan I, dissenting opinion in Louisiana v. Jumel[1] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Sovereign immunity
Louisiana v. Jumel established that lawsuits against state officials are equivalent to lawsuits against states. The Eleventh Amendment of the U.S. Constitution bars suits by citizens against states in federal court on the grounds of sovereign immunity, which protects state governments from civil suits, criminal prosecutions, and other legal actions except when the state has consented to them. The decision of this case extended the Eleventh Amendment and sovereign immunity to include immunity for state officials who are acting on behalf of the state.[1][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Justia, "Louisiana v. Jumel, 107 U.S. 711 (1883)," accessed July 7, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 FindLaw, "STATE OF LOUISIANA EX REL. ELLIOT v. JUMEL," accessed July 7, 2022
- ↑ 3.0 3.1 3.2 3.3 3.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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