Thompson v. Whitman

Decided Supreme Court of the United States
Disposition
affirmed
full scope · unanimous
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Court
Circuit Court for the Southern District of New York
Decided
Judge
Mr. Justice BRADLEY
Posture
Judgment for plaintiff after jury trial
Defendant, Sheriff of Monmouth County, New Jersey (1)
Thompson
Mr. C. N. Blade, Mr. JR. Gilchrist, attorney-general of New Jersey
v.
Plaintiff, citizen of New York (1)
Whitman
Messrs. W. M. Evarts, J. L. Cadwalader

Overview

The judgment of the Circuit Court for the Southern District of New York is affirmed.

Case summary

Thompson v. Whitman involved a trespass action in New York by Whitman, a New York citizen, against Thompson, a New Jersey sheriff, for seizing Whitman's sloop under New Jersey's Oyster Law. Thompson justified the seizure based on a condemnation by New Jersey justices, producing a record stating the seizure occurred within Monmouth County. Whitman challenged jurisdiction, arguing seizure was not in that county. The Supreme Court held that the Full Faith and Credit Clause does not prevent collateral inquiry into the jurisdiction of the court rendering a judgment. The record could be contradicted on jurisdictional facts, and if jurisdiction was lacking, the record was a nullity. Applying New Jersey law, the Court found the justices lacked jurisdiction because the seizure (a single act) did not occur in Monmouth County as required by statute. The Circuit Court's judgment for Whitman was affirmed.

Abstract

Plaintiff sued a sheriff for trespass after seizure of a vessel under state law, challenging the enforcing court's jurisdiction over the location of the seizure. The Supreme Court ruled that the Full Faith and Credit Clause permits collateral inquiry into jurisdictional facts, allowing contradiction of the record, and found jurisdiction lacking under state law since the seizure did not occur in the required county. The lower court's judgment for plaintiff was affirmed.

Opinion of the court

Majority
opinion
Mr. Justice BRADLEY
  • Full Faith and Credit Clause does not bar collateral attack on jurisdiction
  • Jurisdictional facts in record may be contradicted
  • Seizure under NJ law must occur in county for justices to have jurisdiction

Jurisdiction

not challenged
Statutory basis
Article IV, Section 1 of the U.S. Constitution and Act of Congress of May 26, 1790
Subject matter
Federal question involving Full Faith and Credit Clause
Jurisdictional facts
  • Error to Circuit Court for Southern District of New York
  • Case involves interpretation of U.S. Constitution and federal statute

Procedural posture

Posture at trial
Judgment for plaintiff after jury trial
Posture on appeal
Direct appeal on writ of error
Preserved issues
  • Whether record from New Jersey was conclusive evidence of jurisdictional facts
  • Whether seizure was continuous into Monmouth County

Legal categories

BusinessEstate Planning and Real Estate

Case record

Court
Supreme Court of the United States
Trial court
Circuit Court for the Southern District of New York
Decided
Opinion author
Mr. Justice BRADLEY
Opinion type
published
Precedential status
precedential
Judges on panel
Mr. Justice BRADLEY

Issues & holdings

2
Issues raised
2
affirmed
4
Holdings
Standard of review

de novo

Disposition rationale

Record not conclusive; jurisdiction may be collaterally attacked

Preservation

Issue preserved for review

Standard of review

de novo

Disposition rationale

Seizure is single act, not continuous; must occur within county

Preservation

Issue preserved for review

Holdings of the court

Full Faith and Credit Clause effect on jurisdiction
Neither Constitution nor Act of 1790 prevents collateral inquiry into jurisdiction of court rendering judgment
Historical interpretation shows clause regulates effect of acknowledged jurisdiction but does not confer new power; foreign judgments always open to jurisdiction challenge
unanimousbinding precedent
Collateral attack on jurisdictional facts in record
Record may be contradicted as to facts necessary for jurisdiction; if facts didn't exist, record is nullity despite recitals
To allow recitals to prevent inquiry would nullify right to challenge jurisdiction; public policy of extraterritorial recognition differs from domestic
unanimousbinding precedent
Scope of jurisdictional challenges
Want of jurisdiction may be shown as to subject-matter, person, or in rem proceedings as to the thing
Consistent with D'Arcy v. Ketchum and other precedents establishing fundamental requirement of jurisdiction
unanimousbinding precedent
Application to NJ Oyster Law
If seizure not made in county where prosecution occurred, justices lacked jurisdiction under statute
Statute requires seizure in county and trial by justices of that county; seizure is single act, not continuous
unanimousbinding precedent

Error analysis

  • Trial court charged record was only prima facie evidence rather than conclusive — procedural · no error foundNot applicable as no error found · not applicable

Statutory interpretation

2
Statute
New Jersey Oyster Law (1846)
Question
Whether seizure must occur in county for justices to have jurisdiction
Court's reading
Seizure must be made in county; justices of that county only have jurisdiction
Canons applied
Plain meaning
Statute
U.S. Constitution Article IV, Section 1 and Act of Congress May 26, 1790
Question
Whether Full Faith and Credit prevents collateral jurisdiction challenges
Court's reading
Does not prevent inquiry into jurisdiction; regulates effect of acknowledged jurisdiction
Canons applied
Historical interpretationPrecedent analysis

Standards of review

  • Interpretation of Full Faith and Credit Clause — de novo Legal question of constitutional interpretation
  • Jurisdictional facts — de novo Question of law regarding court's authority

Timeline

Procedural path

Oyster law enactedSloop seizedCondemnation proceedingsTrespass action filedJury trial verdictSupreme Court affirmance
6
Events
9,757
Days, incident to ruling
—
Span
factual eventcited in opinion

New Jersey Oyster Law enacted prohibiting non-residents from raking clams/oysters in NJ waters, with forfeiture provisions

Statutory basis for seizure and condemnation

procedural eventcited in opinion

Proceedings before two justices of Monmouth County condemning sloop

Outcome: Condemnation and order of sale

Judgment challenged for lack of jurisdiction

Justices of Monmouth County Monmouth County, NJ trial court
factual eventcited in opinion

Thompson seized Whitman's sloop Anna Whitman in NJ waters

Underlying incident giving rise to litigation

Thompson · Whitman Waters of New Jersey
1862-1863filingcited in opinion

Whitman filed trespass action in Circuit Court for Southern District of New York

Initiated case challenging NJ judgment

Whitman · Thompson trial court
trial eventcited in opinion

Jury trial with special findings: seizure in NJ but not in Monmouth County

Outcome: Verdict for Whitman

Factual findings on jurisdictional issue

Jury · Judge trial court
appeal eventcited in opinion

Supreme Court decision affirming Circuit Court

Outcome: Affirmed

Established precedent on collateral attack of jurisdiction

Mr. Justice BRADLEY appellate court

Facts & evidence

Incident

Date
September 26, 1862
Location
Waters of New Jersey, near Narrows of port of New York

Key facts

5 facts
  1. Whitman, NY resident, raked clams in NJ waters using sloop Anna Whitman
  2. Thompson, NJ sheriff, seized sloop under NJ Oyster Law
  3. Proceedings before two justices of Monmouth County resulted in condemnation
  4. Record stated seizure was within Monmouth County
  5. Whitman sued in NY for trespass, challenging jurisdiction

Disputed questions

  • Whether seizure occurred within Monmouth County
  • Whether justices had jurisdiction

Procedural history

6 steps
  1. Whitman filed trespass action in Circuit Court SDNY
  2. Thompson pleaded justification under NJ law
  3. Jury found seizure was in NJ but not in Monmouth County
  4. Court charged record was only prima facie evidence
  5. Judgment for Whitman
  6. Appeal to Supreme Court

Evidence in the record

Direct
  • Testimony about location of seizure
Documentary
  • Record of New Jersey proceedings
  • New Jersey Oyster Law statute
Challenged
  • Evidence type: Record of New Jersey condemnation · Challenge basis: Jurisdictional facts · Trial court ruling: admitted · Reasoning: Treated as prima facie evidence only · Challenged on appeal: true · Appellate outcome: affirmed

Jury

Verdict
For plaintiff Whitman
Jury instructions given
  • Record was only prima facie evidence of facts stated
Special findings
  • Seizure was within NJ
  • Seizure was not in Monmouth County
  • Plaintiff not taking clams in Monmouth County

Objects of relevance

Sloop Anna Whitman (vessel seized)Clam rakes, tongs, tackle (items subject to forfeiture)

Authorities

Cited authorities (4)

Mills v. Duryee
explainedprecedent
Cited for general effect of judgments under Full Faith and Credit but qualified for jurisdiction challenges
D'Arcy v. Ketchum
followedquotedprecedent
Held judgment void without jurisdiction over person, supporting collateral attack
at 11 Howard 165 Judgment void as to defendant not served
Webster v. Reid
followedprecedent
Held judgments nullities without service, allowing proof of no notice
Christmas v. Russell
citedprecedent
Stated judgments open to inquiry as to jurisdiction and notice

Related cases (3)

Mills v. Duryee
prior appeal
Qualified to allow jurisdiction challenges
D'Arcy v. Ketchum
prior appeal
Held judgment void without jurisdiction over person
Webster v. Reid
prior appeal
Held judgments nullities without service

Statutes

  • New Jersey Oyster Law of 1846
  • Act of Congress of May 26, 1790 (Full Faith and Credit implementation)
  • U.S. Constitution Article IV, Section 1

Standards & doctrines

  • Full Faith and Credit doctrine with jurisdiction exception
  • Political-process doctrine referenced in other cases but not applied here

Legal principles applied

  • Judgment void if court lacks jurisdiction over subject-matter, person, or thing
  • Public acts and records receive faith and credit but not absolute verity extraterritorially
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Action type
affirmed
Target
Circuit Court judgment for plaintiff
Appealed from
Circuit Court for Southern District of New York
Context
Supreme Court affirmed judgment, holding record not conclusive and justices lacked jurisdiction
Scope
full
Disposition vote
unanimous
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