State of Texas v. State of Florida

Decision Date13 March 1939
Docket NumberO,No. 11,11
Citation83 L.Ed. 817,121 A.L.R. 1179,306 U.S. 398,59 S.Ct. 563
PartiesSTATE OF TEXAS v. STATE OF FLORIDA et al. riginal
CourtU.S. Supreme Court

[Syllabus from pages 398-400 intentionally omitted] Messrs. William McCraw, Atty. Gen., Llewellyn B. Duke and William M. Hill, Asst. Attys. Gen., all of Austin, Tex., for State of Texas.

Messrs. John J. Bennett, Jr., Atty. Gen., Seth T. Cole, Sp. Asst. Atty. Gen., Mortimer M. Kassell and William M. O'Reilly, all of Albany, N.Y., for State of New York.

Messrs. George Couper Gibbs, Atty. Gen., and H. E. Carter, Asst. Atty. Gen., both of Tallahassee, Fla., and Edgar G. Hamilton, of West Palm Beach, Fla., for State of Florida.

Messrs. Paul A. Dever, Atty. Gen., Edward O. Proctor, Asst. Atty. Gen., and Henry F. Long, all of Boston, Mass., and T. Ludlow Chrystie, of New York City, for State of Massachusetts.

Messrs. Harrison Tweed, Timothy N. Pfeiffer, Walter E. Hope, and George W. Jaques, all of New York City, for Wilks.

Mr. Justice STONE delivered the opinion of the Court.

This original suit, in the nature of a bill of interpleader, brought to determine the true domicile of decedent as the basis of rival claims of four states for death taxes upon his estate, raises two principal questions: Whether this Court has jurisdiction of the cause and, if so, whether the report of the Special Master, finding that decedent at the time of his death was domiciled in Massachusetts, should be confirmed.

On March 15, 1937, this Court granted the motion of the State of Texas for leave to file its bill of complaint against the States of Florida and New York and the Commonwealth of Massachusetts, and against decedent's wife, Mabel Harlow Green, and his sister, Hetty Sylvia Ann Howland Green Wilks, both alleged to be residents of New York. The bill of complaint alleges that Edward H. R. Green died at Lake Placid, New York, on June 8, 1936, leaving surviving him his wife and sister as his only heir and next of kin; that he left a gross estate of approximately $44,348,500, and a net estate valued at $42,348,500, comprising real estate and tangible personal property located in Taxas, New York, Florida and Massachusetts, of an aggregate value of approximately $6,500,000, and intangible personal property consisting principally of stocks, bonds and securities, the paper evidences of most of which were located in New York.

The bill of complaint alleges that decedent, at the time of his death, was domiciled in Texas, but that Florida, New York, and Massachusetts each asserts, through its taxing officials, that decedent was at the time of his death domiciled within it. It alleges in detail that Texas and each of the defendant states maintains and enforces a system of taxation upon the inheritance or succession of the estates of decedents domiciled within the state at death, under which laws real estate and tangible personal property located within the state and all intangibles, regardless of their situs, are subjected to the tax; that each of the four states asserts and proposes to exercise the right to tax the estate of decedent on the assumption that decedent was domiciled within it at the time of his death; and that certain judicial proceedings have been instituted in each of the four states for the administration of decedent's estate or some parts of it.1 It is further alleged that none of the four states and no officer or representative of any state, except as already noted, has become a party to any of those proceedings, and that no state or its officer or representative will appear or become a party to any such proceedings instituted in any other state to fix or assess death taxes on decedent's estate, and that no judgment in any such proceeding will be binding on any state not a party to it; that each of the four states claims a lien for taxes and the right to collect a tax, based on decedent's alleged domicile within it, upon the tangibles located in the state and upon all decedent's intangibles wherever located, the total of such claims amounting to a sum far greater than the net value of the estate; that the amount of decedent's property located in Texas is negligible in amount and insufficient to pay its tax; and in the event that the states should obtain adjudications in their own or other courts in pending proceedings, or others instituted for the purpose of collecting the tax on the ground that decedent was domiciled elsewhere than in Texas, Texas would be deprived of its lawful tax. The bill prays that the Court determine whether decedent's domicile for purposes of taxation, was in either of the defendant states and that particularly it determine and adjudicate that his domicile was in Texas and that it alone has the right to assess and collect death taxes on decedent's intangibles.

The several defendant states, answering, admit that decedent's estate is insufficient to satisfy the total amount of the taxes claimed. All deny that Green was domiciled in Texas, and by way of counterclaim and cross-bill against the other defendants, each asserts that he was domiciled in it and that it is entitled to collect death taxes upon all of decedent's intangible property and upon all his tangibles within the state. The answer of decedent's wife admitted that he was domiciled in Texas and asserted that by Texas law she owned, as community property, one-half of substantially all of decedent's estate acquired by him after their marriage, free and clear of all death taxes. Pursuant to stipulation showing that she had released all interest in decedent's estate, the suit was dismissed as to her by order of the Court on January 17, 1938. 302 U.S. 662, 58 S.Ct. 478, 82 L.Ed. 511. The answer of defendant Wilks, decedent's sister, denies that Green was domiciled in Texas and asks the Court to determine in which of the defendant states he was domiciled for purposes of taxation.

On June 1, 1937, this Court appointed a Special Master, 301 U.S. 671, 57 S.Ct. 935, 81 L.Ed. 1335, to take evidence, to make findings of fact and state conclusions of law, and to submit them to this Court, together with his recommendations for a decree. The Special Master has reported his findings, with certain evidentiary facts, and his finding that decedent at the time of his death was domiciled in the Commonwealth of Massachusetts, this latter conclusion being supported by elaborate subsidiary findings. The case is now before us on exceptions to the Special Master's conclusions of fact and subsidiary findings that decedent's domicile was in Massachusetts at the time of his death.

Jurisdiction.

While the exceptions do not challenge the jurisdiction of the Court, the novel character of the questions presented and the duty which rests upon this Court to see to it that the exercise of its powers be confined within the limits prescribed by the Constitution make it incumbent upon us to inquire of our own motion whether the case is one within its jurisdiction. Minnesota v. Hitchcock, 185 U.S. 373, 382, 385, 22 S.Ct. 650, 654, 46 L.Ed. 954. By the Judiciary Article of the Constitution, the judicial power extends to controversies between states, and this Court is given original jurisdiction of cases in which a state shall be a party. Art. 3, § 2, U.S.C.A.Const. The present suit is between states, and the other jurisdictional requirements being satisfied, the individual parties whose presence is necessary or proper for the determination of the case or controversy between the states are properly made parties defendant. Cf. United States v. West Virginia, 295 U.S. 463, 470, 55 S.Ct. 789, 791, 79 L.Ed. 1546. So that our constitutional authority to hear the case and grant relief turns on the question whether the issue framed by the pleadings constitutes a justiciable 'case' or 'controversy' within the meaning of the Constitutional provision, and whether the facts alleged and found afford an adequate basis for relief according to accepted doctrines of the common law or equity systems of jurisprudence, which are guides to decision of cases within the original jurisdiction of this Court. See Robinson v. Campbell, 3 Wheat. 212, 222, 223, 4 L.Ed. 372; Pennsylvania v. Wheeling & Belmont Bridge Co., 18 How. 460, 462, 15 L.Ed. 449; Irvine v. Marshall, 20¢how. 558, 564, 565, 15 L.Ed. 994; Payne v. Hook, 7 Wall. 425, 430, 19 L.Ed. 260.

Before the Constitution was adopted a familiar basis for the exercise of the extraordinary powers of courts of equity was the avoidance of the risk of loss ensuing from the demands in separate suits of rival claimants to the same debt or legal duty. Alnete v. Bettam, Cary, 65 (1560); Hackett v. Webb and Willey, Finch 257 (1676); see 9 Viner Abr., 419—440; 1 Spence, The Equitable Jurisdiction of the Court of Chancery, 659; Maclennan, Law of Interpleader, 5 et seq. Since, without the interposition of equity, each claimant in pursuing his remedy in an independent suit might succeed and thus subject the debtor or the fund pursued to multiple liability, equity gave a remedy by way of bill of interpleader, upon the prosecution of which it required the rival claimants to litigate in a single suit their ownership of the asserted claim. A plaintiff need not await actual institution of independent suits; it is enough if he shows that conflicting claims are asserted and that the consequent risk of loss is substantial. Evans v. Wright, 13 W.R. 468; Michigan Trust Co. v. McNamara, 165 Mich. 200, 130 N.W. 653, 37 L.R.A.,N.S., 986; Webster v. Hall, 60¢n.H. 7; Thomson v. Ebbets, 1 Hopk. Ch., N.Y., 272; Dorn v. Fox, 61 N.Y. 264; Yarborough v. Thompson, 3 Smedes & M. 291, 11 Miss. 291, 294, 41 Am.Dec. 626; 4 Pomeroy, Equity Jurisprudence (4th ed.) §§ 1319 1329, 1458—1482; Maclennan, supra, 119.

The peculiarity of the strict bill of interpleader was that the plaintiff asserted no interest in the debt or fund, the amount of which he placed at the disposal of the court and asked...

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