Overview
Case summary
The State of Washington brought a mandamus action in state court against the Northern Pacific Railroad Company and its federal court-appointed receiver, Andrew F. Burleigh, to compel compliance with a state law requiring railroads to construct scales and have lumber/shingles weighed before out-of-state shipment. The defendants removed the case to federal circuit court, and the state moved to remand, arguing lack of federal jurisdiction. The court denied the motion to remand, holding that when a federal court appoints a receiver and assumes exclusive control over railroad operation, any suit against the receiver in official capacity intended to affect railroad business is ancillary to the main receivership case, giving federal court jurisdiction over such ancillary suits.
Abstract
The state brought a mandamus action in state court against a railroad company and its federal court-appointed receiver to compel compliance with a state law on weighing lumber and shingles before out-of-state shipment. The defendants removed the case to federal court, and the state moved to remand arguing lack of federal jurisdiction. The court denied remand, holding that suits against the receiver in official capacity affecting railroad operations are ancillary to the main receivership case, conferring federal jurisdiction.
Opinion of the court
opinionHANFORD, District Judge
- Federal court has exclusive control over railroad operation through receivership
- Suits against receiver in official capacity affecting railroad business are ancillary to main receivership case
- Ancillary suits are within federal court jurisdiction and removable from state court
Jurisdiction
challenged- Receiver appointed by federal court
- Suit against receiver in official capacity
- Action intended to affect operation of railroad business
Procedural posture
- Jurisdiction of federal court over ancillary suits against receiver
Legal categories
Case record
Issues & holdings
Not specified
Court finds jurisdiction because suit is ancillary to main receivership case
Issue preserved for review
Holdings of the court
Error analysis
- State argued federal court lacked jurisdiction because action was not a civil action and insufficient amount involved — procedural · no error foundnot applicable
Statutory interpretation
1Standards of review
- Jurisdiction over ancillary suit against receiver — de novo Jurisdictional questions typically reviewed de novo
Timeline
State of Washington enacts law requiring trans-continental railroads to construct scales and have lumber/shingles weighed by official weigher before out-of-state shipment
Creates statutory duty that forms basis of state's mandamus action
Federal circuit court denies state's motion to remand case to state court
Outcome: Motion to remand denied
Court asserts federal jurisdiction over ancillary suit against receiver
Federal circuit court appoints Andrew F. Burleigh as receiver for Northern Pacific Railroad Company
Establishes federal court's exclusive control over railroad operation, creating basis for ancillary jurisdiction
State of Washington files action for writ of mandate in state superior court to compel compliance with 1895 law
Initiates legal proceedings that are subsequently removed to federal court
Defendants remove case from state court to federal circuit court
Brings case into federal forum where jurisdiction is contested
Facts & evidence
Incident
Key facts
5 facts- State enacted law in 1895 requiring trans-continental railroads to construct scales for weighing lumber/shingles cars
- Law required official weigher appointed by governor to weigh all lumber/shingles for out-of-state shipment
- Railroad required to pay 50 cents per car to official weigher
- Receiver appointed by federal court to operate Northern Pacific Railroad
- State brought mandamus action to compel compliance with state law
Procedural history
3 steps- Action commenced in state superior court
- Defendants removed case to federal circuit court
- State moved to remand case to state court
Evidence in the record
- Laws Wash. 1895, p. 380 (state statute requiring weighing of lumber/shingles)
Authorities
Cited authorities (1)
Statutes
- Laws Wash. 1895, p. 380 (state weighing requirement statute)
Standards & doctrines
- Ancillary jurisdiction doctrine for suits against federal court-appointed receivers
Legal principles applied
- Complete jurisdiction over receivership assets draws ancillary suits into federal court jurisdiction
- Suits against receiver in official capacity affecting business are ancillary to main receivership case