County of Lewis v. United States

No. 58
Decided District Court, D. Montana
Disposition
sustained
full scope · unanimous
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Court
District Court, D. Montana
Decided
Judge
KNOWLER, District Judge
Posture
Demurrer to petition pending
Plaintiff (1)
COUNTY OF LEWIS AND CLARKE
R. R. Purcell, for plaintiff
v.
Defendant (1)
UNITED STATES
P. H. Leslie, U. S. Atty.

Overview

The demurrer is sustained.

Case summary

The County of Lewis and Clarke, Montana, sued the United States to recover rent for the use of its county jail to confine federal prisoners. The United States demurred, challenging the legal sufficiency of the petition. The court addressed two main issues: (1) interpretation of a Montana statute requiring payment of 'ten dollars per month to the county, for the use of the jail' for federal prisoners, and (2) whether the state statute could bind the federal government. The court held that the statute meant $10 per month for all prisoners confined, not $10 per month per prisoner, finding no ambiguity justifying a different reading. Additionally, the court held that the state statute was not binding on the United States, as federal law (Rev. St. § 5547) made the confinement of federal prisoners a matter of contract to be arranged by the Attorney General, and no contract was alleged. The demurrer was sustained, dismissing the county's claim.

Abstract

A county sued the United States to recover rent for using its jail to house federal prisoners under a state statute requiring payment of ten dollars per month for the jail's use. The court interpreted the statute as applying $10 per month for all prisoners collectively, not per prisoner, and held that the state statute did not bind the federal government absent a contract arranged by the Attorney General as required by federal law. The demurrer was sustained, dismissing the claim.

Opinion of the court

Majority
opinion
KNOWLER, District Judge
  • Montana statute means $10 per month for all prisoners, not per prisoner
  • State statute not binding on United States without contract
  • Federal law controls confinement of federal prisoners through Attorney General's contracting authority

Jurisdiction

not challenged
Subject matter
Federal question involving interpretation of state statute and federal law regarding confinement of United States prisoners
Jurisdictional facts
  • Action brought by county against United States to recover rent for county jail use

Procedural posture

Posture at trial
Demurrer to petition pending
Posture on appeal
Not applicable (trial court decision)
Preserved issues
  • Construction of Montana statute
  • Binding effect of state statute on United States

Legal categories

Business

Case record

Full case name
COUNTY OF LEWIS AND CLARKE v. UNITED STATES
Docket number
No. 58
Court
District Court, D. Montana
Trial court
District Court, D. Montana
Trial court judge
KNOWLER, District Judge
Decided
Opinion author
KNOWLER, District Judge
Opinion type
published
Precedential status
persuasive
Judges on panel
KNOWLER, District Judge

Issues & holdings

2
Issues raised
2
affirmed
2
Holdings
Standard of review

de novo

Disposition rationale

Statute means $10 per month for all prisoners, not per prisoner; no ambiguity justifies adding terms

Preservation

Issue preserved for review

Standard of review

de novo

Disposition rationale

State statute not binding on United States without consent; federal law makes confinement matter of contract controlled by attorney general

Preservation

Issue preserved for review

Holdings of the court

Interpretation of Montana statute regarding jail rent
Montana statute means $10 per month to the county for the use of the jail for all United States prisoners confined, not $10 per month for each prisoner
Statute provides payment 'for the use of the jail' for persons committed, not per person; no ambiguity justifies adding terms; historical construction does not support per-prisoner interpretation
unanimousnon-binding
Binding effect of state statute on United States
Montana statute is not binding on the United States; payment for jail use must rest in contract, express or implied, under federal law
United States not bound by state statute without consent; Rev. St. § 5547 makes confinement of federal prisoners matter of contract controlled by attorney general; no contract alleged in petition
unanimousnon-binding

Statutory interpretation

2
Statute
Montana Comp. St. § 1275
Question
Whether 'ten dollars per month to the county, for the use of the jail' means $10 per month per prisoner or $10 per month for all prisoners
Court's reading
$10 per month for all prisoners confined, not per prisoner
Canons applied
Plain meaningNo addition of terms to statute
Statute
Rev. St. § 5547
Question
Whether federal law preempts state statute regarding confinement of federal prisoners
Court's reading
Federal law makes confinement matter of contract controlled by Attorney General, not subject to state statute
Canons applied
Federal supremacy

Standards of review

  • Construction of Montana statute — de novo Statutory interpretation reviewed de novo
  • Binding effect of state statute on United States — de novo Legal question of federal-state relations reviewed de novo

Timeline

3
Events
324
Days, incident to ruling
—
Span
filingcited in opinion

County of Lewis and Clarke filed petition against United States seeking judgment for rent of county jail

Outcome: Petition filed

Initiates legal action to recover jail rent from federal government

Construction of Montana statuteBinding effect of state statute on United States
COUNTY OF LEWIS AND CLARKE · UNITED STATES trial court
motioncited in opinion

United States filed demurrer to petition alleging it did not state facts sufficient to constitute cause of action

Outcome: Demurrer filed

Challenges legal sufficiency of county's claim

Construction of Montana statuteBinding effect of state statute on United States
UNITED STATES · P. H. Leslie, U. S. Atty. trial court
rulingcited in opinion

Court sustained demurrer, holding Montana statute means $10 per month for all prisoners, not per prisoner, and state statute not binding on United States without contract

Outcome: Demurrer sustained

Final disposition dismissing county's claim

Construction of Montana statuteBinding effect of state statute on United States
KNOWLER, District Judge trial court

Facts & evidence

Incident

Location
County of Lewis and Clarke, state of Montana

Key facts

3 facts
  1. County sued United States for rent of county jail used for federal prisoners
  2. United States demurred to petition alleging insufficient facts
  3. Dispute centers on interpretation of Montana statute regarding payment for jail use

Procedural history

3 steps
  1. County filed petition seeking judgment for jail rent
  2. United States demurred to petition
  3. Court heard arguments on demurrer

Evidence in the record

Documentary
  • Montana statute Comp. St. § 1275
  • Federal statute Rev. St. § 5547
Challenged
  • Evidence type: Montana statute Comp. St. § 1275 · Challenge basis: Interpretation of payment terms · Trial court ruling: admitted · Reasoning: Statute interpreted to mean $10 per month for all prisoners, not per prisoner · Challenged on appeal: false · Appellate outcome: not applicable

Objects of relevance

County jail of Lewis and Clarke County (subject of rent dispute)

Authorities

Cited authorities (2)

Comp. St. § 1275
interpretedquotedprecedent
Montana statute providing for payment of $10 per month to county for use of jail for federal prisoners
at Full statute quoted in opinion Statute interpreted to mean $10 per month for all prisoners, not per prisoner
Rev. St. § 5547
appliedquotedprecedent
Federal statute requiring Attorney General to contract for imprisonment of federal prisoners in state or territorial facilities
at Cited as controlling federal law Makes confinement matter of contract, not subject to state statute

Statutes

  • Montana Comp. St. § 1275 (state jail payment statute)
  • Rev. St. § 5547 (federal prisoner confinement contracting statute)

Standards & doctrines

  • Plain meaning doctrine in statutory interpretation
  • Federal contracting authority doctrine under Rev. St. § 5547

Legal principles applied

  • Plain meaning rule in statutory interpretation
  • Federal supremacy in matters of federal prisoner confinement
  • Requirement of contract for federal payment obligations under state laws
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Entities and documentation
Legal actions
Action type
sustained
Target
demurrer to petition
Appealed from
Not applicable
Context
Court sustained demurrer filed by United States, holding petition did not state facts sufficient to constitute cause of action due to statutory interpretation and lack of contract
Scope
full
Further instructions
None specified
Disposition vote
unanimous
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