Courts exercise two types of jurisdiction over cases: original jurisdiction and appellate jurisdiction for cases previously heard in a lower court. Judges have the option, when hearing an appeals case, to reverse or remand a decision based on a violation of law like abuse of discretion.
What Is the Court's Function in General?
Whether it is dealing with two neighbors squawking over an overgrown shrub or sentencing a murderer to many years in prison, a court's function is essentially to keep the peace. A court, whether municipal, state or federal, is made up of an unbiased group of judges who hear testimony, weigh evidence and rule on the outcome of a civil or criminal trial.
There are three levels of courts: municipal courts, state courts and federal courts. Each level of court exercises jurisdiction, or its authority to hear a case, based on a few factors. With attention to jurisdiction, we will study original and appellate jurisdiction in state and federal courts.
Original Jurisdiction
Keep in mind that no one state court behaves exactly as another, meaning state courts have different procedures and rules. As we learn about jurisdiction, we will focus on a general rule not specific to any one state.
Again, jurisdiction is a court's authority to hear a case. There are two types of jurisdiction: jurisdiction over property and people, and subject matter jurisdiction.
To keep things simple, jurisdiction over property is used to seize a valuable asset needed to make restitution to an injured party or to entice a defendant to appear in court. On the other hand, jurisdiction over people is decided based on whether a party to the suit lives in the forum state or the state in which the tort or criminal act took place.
Subject matter jurisdiction is used based on the nature of the case. For instance, a murder trial will be heard in criminal court while divorce proceedings will be heard in family court (depending on the state).
Sometimes, a defendant to a case lives outside of the forum state, or state to which the case is being tried. When this happens, long-arm statute is used to bring an out-of-state defendant to trial in the forum state.
Bringing an out-of-state defendant to trial in another state is not cut and dry. Minimum contact with the forum state needs to be established. To say it a different way, to exercise jurisdiction over a defendant in a different state, the court must prove that this defendant has minimum contact in the forum state either by residence or business dealings.
As an illustration, in International Shoe v. State of Washington (1945), International Shoe Company was a shoe manufacturer with its headquarters in Delaware and its manufacturing plant in Missouri. The state of Washington brought suit against International Shoe, a Delaware company with manufacturing done in yet another state, for unpaid employment tax for employees who resided in Washington State and worked for the company.
Even though International Shoe did not conduct official business, like having official storefronts, in Washington, the state sought to collect taxes from the company by reason of minimum contact.
In the end, minimum contact was established based on a few factors:
- International Shoe salesmen who resided in Washington made regular wages
- Salesmen set up mock stores where samples could be tried and orders were taken
- The company benefited from the laws of Washington
In sum, original jurisdiction can be extended over property and people as well as subject matter. Broad jurisdiction is typical of state courts. Appellate courts exercise a more limited jurisdiction over cases.
Appellate Jurisdiction
Appellate courts hear cases moved up from a lower court when one or more parties to a case is not satisfied with the lower court's ruling. Both federal and state appellate courts work in mostly the same way. Once a lower court has made a ruling, one or more of the parties may request that a higher court hear the case.
Once the disgruntled party or parties files an appeal, this higher court will hear the case only if the issue for appeal stems from an issue of the application of law or where there was a violation of one's rights under the Constitution. No new evidence can be presented nor will a new trial, per se, take place.
The judges or justices will review the ruling and rationale for the lower court judgment and make a decision to affirm, remand or reverse the ruling.
Decisions, Decisions
If a decision is affirmed, the higher court is simply confirming the decision of the lower court and no further action can be taken. A case is remanded when it is sent back to lower court for further action based on the judge's review and advice.
In Gideon v. Wainwright (1963), a young, homeless Clarence Earl Gideon was tried and convicted of a misdemeanor crime in the state of Florida. At the time, Florida held that in exception of one's Sixth Amendment right to counsel, a misdemeanor crime did not qualify.
As a result, Gideon unsuccessfully represented himself and was found guilty of petty larceny and burglary. While serving his prison term, Gideon began studying the law and discovered that his Sixth Amendment right was, in fact, violated.
For that, Gideon filed a writ of habeas corpus, or a claim of false imprisonment, with the U.S. Superior Court on the basis of a violation of his constitutional rights. It was found that Gideon's right to counsel was violated.
Gideon's case was remanded back to lower court where he was appointed an attorney to represent his rights. He was found not guilty.
There are times when an appellate court actually reverses the decision of a lower court ruling by annulling the judgment made in a previous trial because there was a violation of law or constitution. Specifically, in Lochner v. State of New York (1905), the state of New York restricted the number of hours a bakery employee could work to less than 60 hours a week.
Lochner, a baker out of Utica, New York, argued that the law restricted the products he could produce, thereby violating his Fourteenth Amendment to right to life, liberty or property without due process. The state of New York claimed that having workers exceed 60 hours was dangerous, and they required ample rest between shifts.
