In the matter of James v. City of Boise, Idaho (136 S.Ct. 685 (2016)), the Supreme Court of the United States has clarified for all state courts, including Pennsylvania, who/what has the ultimate authority, and indeed the jurisdiction, to interpret and apply federal law.
The Plaintiff in the James matter filed a claim under 42 U.S.C. Section 1983 against the city of Boise and some of its police officers after she was bitten by one of their police dogs while they were responding to a burglary call.
Plaintiff brought suit in her local state trial court. Plaintiff was unsuccessful at trial which led to her appealing the matter all the way to Idaho’s Supreme Court. The Idaho Supreme Court affirmed the dismissal of Plaintiff’s case and awarded the Defendants appellate attorneys’ fees. Plaintiff again appealed, this time to the Supreme Court of the United States.
Pursuant to 42 U.S.C. Section 1983, the court may elect to award reasonable attorneys’ fees to a prevailing party in a civil rights law suit. The United States Supreme Court, in the matter of Hughes v. Rowe, 449 U.S. 5 (1980), interpreted 42 U.S.C. Section 1988 to allow attorneys’ fees to be assessed only if the underlying action was frivolous, unreasonable, or without foundation.
When deciding the James case, the Idaho Supreme Court decided, unilaterally, that it was not bound by United States Supreme Court’s interpretation of 42 U.S.C. Section 1988 as enunciated in the Hughes matter. The logic employed by the Idaho Supreme Court led it to conclude that while the United States Supreme Court can determine how federal courts can assess attorneys’ fees, it has no authority to do so for state courts such as the Idaho Supreme Court. As a result, the Idaho Supreme Court ruled that it, and/or its lower courts, could assess attorneys’ fees without a prior determination of whether the underlying matter was frivolous, unreasonable, or without foundation.
Upon review of the Idaho Supreme Court, the United States Supreme Court, in no uncertain terms, reversed the Idaho Supreme Court, indicating that federal statutes are definitively interpreted by federal courts, with the Supreme Court, of course, being the ultimate authoritative federal court, and those interpretations, must be respected by state courts.
In support of its decision, the United States Supreme Court went back to 1816 in citing Justice Story in Martin v. Hunter’s Lessee, 1 Wheat. 304, 348 when he ruled “the laws, the treaties, and the constitution of the United State would be different in different states, and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two states. The public mischiefs that would attend such a state of things would be truly deplorable.”
In short, the Idaho courts, or the courts of any state including those in Pennsylvania, are bound by the United States Supreme Court’s interpretation of federal law regardless of whether the underlying matter is a state case or in state court.
Originally published in The Legal Intelligencer Blog on April 7, 2016 and can be seen here.