Wednesday, January 27, 2016

Idaho is still part of the United States

Federal laws apply everywhere, from Maine to San Diego. State courts cannot interpret federal laws as they see fit. They have to follow Supreme Court authority. In this case, the Supreme Court slaps down a court in Idaho that thought otherwise.

The case is James v. City of Boise, decided on January 25. The issues here were so clear-cut that the Supreme Court decided the case without oral argument. Under a federal statute that we call Section 1988, in civil rights cases, the prevailing plaintiff can recover his attorneys' fees from the losing party. But that is a one-way street. "Loser pays" does not apply when the defendant wins the case. When the defendant wins, the plaintiff pays the defendant nothing, unless the case was completely frivolous and off-the-wall. The Supreme Court has interpreted Section 1988 that way for years.

A plaintiff in Idaho brought a civil rights case against a city and lost. The plaintiff wanted damages after she was bitten by a police dog when she was mistaken for a burglar. The state court in Idaho decided that Section 1988 required the plaintiff to pay the City its attorneys' fees solely on the ground that the City won the case. The court did not decide whether the lawsuit was frivolous. That was wrong, and the Supreme Court reminds us that federal law reigns supreme in the U.S., and that state courts have to follow Supreme Court precedent.

The Idaho court noted that Section 1988 is a federal statute. But it also said it could interpret the statute in its own way:

Although the Supreme Court may have the authority to limit the discretion of lower federal courts, it does not have the authority to limit the discretion of state courts where such limitation is not contained in the statute. Therefore, in cases filed in the Idaho state courts seeking to recover under 42 U.S.C. section 1988, the court has discretion in deciding to award attorney fees to the prevailing party, whether the prevailing party is the plaintiff or the defendant.

Not so, the Supreme Court says:

“It is this Court’s responsibility to say what a [federal] statute means, and once the Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law.” And for good reason. As Justice Story explained 200 years ago, if state courts were permitted to disregard this Court’s rulings on federal law, “the laws, the treaties, and the constitution of the United States 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.” Martin v. Hunter’s Lessee, 1 Wheat. 304, 348 (1816).
Do you see that case citation from 1816? That was a Supreme Court case that foreshadowed cases like this one. All laws students read Martin v. Hunter's Lessee. No one remembers the facts in that case, and many of us have probably forgotten its holding. The modern Supreme Court reminds us of that holding in this case. 

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