parent nodes: federal habeas jurisdiction | judicial power
Sheldon v Sill
Facts
Hastings, an MI citizen, assigns a promissory note to Sill, an NY citizen
Sill files suit against Sheldon, an MI citizen, in circuit court to recover on a promissory note
§ 11 of the Judiciary Act prohibits suits on an assigned note unless the first bearer could get jurisdiction to sue
Sill claims that § 11 is unconstitutional under Article III
Issue: Has the court jurisdiction?
Analysis
If the Constitution required lower federal courts, then the lower federal courts would have the full extent of Article III, § 2 judicial power. But since the Constitution does not require lower federal courts, either (1) every inferior court that Congress does create must have the full range of Article III, § 2 power, or (2) Congress may define the jurisdiction of each inferior court that it creates. Since (1) "could not be defended with any show of reason," (2) must follow.
Because Congress may define the jurisdiction of each inferior court it creates, by negative implication "(c)ourts created by statute can have no jurisdiction but such as the statute confers." As a result, because Congress can positively define the jurisdiction of the courts, Congress may also withhold jurisdiction. Because Article III allows Congress to withdraw jurisdiction, § 11 is valid, and Sheldon must lose.
Note that Grier argues in dicta that "the Constitution hs defined the limits of the judicial power . . . but has not prescribed how much of it shall be exercised" by lower courts; as a result, "the statute that prescribes the limits of their jurisdiction, cannot be in conflict with the Constitution, unless it confers powers not enumerated therein."
judicial power