New York v. Connecticut
Encyclopedia
New York v. Connecticut, 4 U.S. 1
(1799), was a lawsuit heard by the Supreme Court of the United States
between the State
of New York
against the State of Connecticut
in 1799 that arose from a land dispute between private parties. It was the first case in which the Supreme Court exercised its original jurisdiction
under Article III of the United States Constitution to hear controversies
between two states.
. Connecticut claimed jurisdiction over the land, and granted
it to Jeremiah Halsey and Andrew Ward in exchange for their construction of the state house in Hartford
.
After the State of New York granted certain parcels within the Connecticut Gore to other individuals, the successors in title
to Halsey and Ward filed an action for ejectment
in the United States Circuit Court for the District of Connecticut
. The defendants argued that they were residents of New York and that the land was actually in Steuben County, New York
; only state or federal courts in New York could accordingly exercise jurisdiction
over the action. The plaintiffs claimed that the lands were instead in Connecticut.
The Supreme Court denied a motion
to remove
the cases from the Circuit Court, and New York subsequently filed a bill in equity against Connecticut and the Connecticut plaintiffs for an injunction
to stay
the ejectment proceedings. As part of the bill, New York submitted an agreement between the states, dated November 28, 1683, that purported to recognize New York's rights to the land.
Because the bill in equity was filed while the Connecticut General Assembly
was out of session, the State never actually participated in the case. However, attorneys for the private land claimants argued that reasonable notice
was not given for the injunction to be granted, and that regardless, New York lacked an interest in the proceedings to merit a stay.
was sufficient, because a shorter period of time may be reasonable when the application for injunction is made to a court rather than a single judge. However, the Court denied the injunction, finding that New York lacked standing
. It was not a party to the suits in the lower court, nor did it have a concrete interest in the decisions. The State was claiming jurisdiction over the land, not title to it, and the Circuit Court lacked the power to determine the State's boundaries and its consequent rights.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1799), was a lawsuit heard by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
between the State
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
of New York
New York
New York is a state in the Northeastern region of the United States. It is the nation's third most populous state. New York is bordered by New Jersey and Pennsylvania to the south, and by Connecticut, Massachusetts and Vermont to the east...
against the State of Connecticut
Connecticut
Connecticut is a state in the New England region of the northeastern United States. It is bordered by Rhode Island to the east, Massachusetts to the north, and the state of New York to the west and the south .Connecticut is named for the Connecticut River, the major U.S. river that approximately...
in 1799 that arose from a land dispute between private parties. It was the first case in which the Supreme Court exercised its original jurisdiction
Original jurisdiction
The original jurisdiction of a court is the power to hear a case for the first time, as opposed to appellate jurisdiction, when a court has the power to review a lower court's decision.-France:...
under Article III of the United States Constitution to hear controversies
Case or controversy
The Case or Controversy Clause of Article III of the United States Constitution has been deemed to impose a requirement that United States federal courts are not permitted to hear cases that do not pose an actual controversy — that is, an actual dispute between adverse parties which is capable of...
between two states.
Background of the case
The "Connecticut Gore" region was a strip of land on New York's western border with PennsylvaniaPennsylvania
The Commonwealth of Pennsylvania is a U.S. state that is located in the Northeastern and Mid-Atlantic regions of the United States. The state borders Delaware and Maryland to the south, West Virginia to the southwest, Ohio to the west, New York and Ontario, Canada, to the north, and New Jersey to...
. Connecticut claimed jurisdiction over the land, and granted
Land grant
A land grant is a gift of real estate – land or its privileges – made by a government or other authority as a reward for services to an individual, especially in return for military service...
it to Jeremiah Halsey and Andrew Ward in exchange for their construction of the state house in Hartford
Hartford, Connecticut
Hartford is the capital of the U.S. state of Connecticut. The seat of Hartford County until Connecticut disbanded county government in 1960, it is the second most populous city on New England's largest river, the Connecticut River. As of the 2010 Census, Hartford's population was 124,775, making...
.
After the State of New York granted certain parcels within the Connecticut Gore to other individuals, the successors in title
Title (property)
Title is a legal term for a bundle of rights in a piece of property in which a party may own either a legal interest or an equitable interest. The rights in the bundle may be separated and held by different parties. It may also refer to a formal document that serves as evidence of ownership...
to Halsey and Ward filed an action for ejectment
Ejectment
Ejectment is the common law term for civil action to recover the possession of and title to land. It replaced the old real actions as well as the various possessory assizes...
in the United States Circuit Court for the District of Connecticut
United States circuit court
The United States circuit courts were the original intermediate level courts of the United States federal court system. They were established by the Judiciary Act of 1789. They had trial court jurisdiction over civil suits of diversity jurisdiction and major federal crimes. They also had appellate...
. The defendants argued that they were residents of New York and that the land was actually in Steuben County, New York
Steuben County, New York
Steuben County is a county located in the U.S. state of New York. As of the 2010 census, the population was 98,990. Its name is in honor of Baron von Steuben, a German general who fought on the American side in the American Revolutionary War, though it is not pronounced the same...
; only state or federal courts in New York could accordingly exercise jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
over the action. The plaintiffs claimed that the lands were instead in Connecticut.
The Supreme Court denied a motion
Motion (legal)
In law, a motion is a procedural device to bring a limited, contested issue before a court for decision. A motion may be thought of as a request to the judge to make a decision about the case. Motions may be made at any point in administrative, criminal or civil proceedings, although that right is...
to remove
Removal
Removal may refer to:* Removal * Removal jurisdiction in the United States courtsRemoval may also indirectly refer to:* Administrative removal in immigration law* Amputation, removal of a body extremity by trauma or surgery...
the cases from the Circuit Court, and New York subsequently filed a bill in equity against Connecticut and the Connecticut plaintiffs for an injunction
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
to stay
Stay of proceedings
A stay of proceedings is a ruling by the court in civil and criminal procedure, halting further legal process in a trial. The court can subsequently lift the stay and resume proceedings. However, a stay is sometimes used as a device to postpone proceedings indefinitely.-United Kingdom:In United...
the ejectment proceedings. As part of the bill, New York submitted an agreement between the states, dated November 28, 1683, that purported to recognize New York's rights to the land.
Because the bill in equity was filed while the Connecticut General Assembly
Connecticut General Assembly
The Connecticut General Assembly is the state legislature of the U.S. state of Connecticut. It is a bicameral body composed of the 151-member House of Representatives and the 36-member Senate. It meets in the state capital, Hartford. There are no term limits for either chamber.During...
was out of session, the State never actually participated in the case. However, attorneys for the private land claimants argued that reasonable notice
Notice
Notice is the legal concept in which a party is made aware of a legal process affecting their rights, obligations or duties. There are several types of notice: public notice , actual notice, constructive notice, and implied notice....
was not given for the injunction to be granted, and that regardless, New York lacked an interest in the proceedings to merit a stay.
The court's decision
The Court found that noticeNotice
Notice is the legal concept in which a party is made aware of a legal process affecting their rights, obligations or duties. There are several types of notice: public notice , actual notice, constructive notice, and implied notice....
was sufficient, because a shorter period of time may be reasonable when the application for injunction is made to a court rather than a single judge. However, the Court denied the injunction, finding that New York lacked standing
Standing (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...
. It was not a party to the suits in the lower court, nor did it have a concrete interest in the decisions. The State was claiming jurisdiction over the land, not title to it, and the Circuit Court lacked the power to determine the State's boundaries and its consequent rights.
Further reading
- The Connecticut Gore Title, Stated and Considered, Showing The Right of the Proprietors, to the Lands Lately Purchased by Them, from the State of Connecticut: Lying West of the Delaware River. Hudson & Goodwin (Hartford, 1799). An advocacy for Connecticut's right to the land, which contains the text of eighteen original documents pertaining to the land dispute dating back to 1631.
- The Rise, programs, and effect of the claim of the proprietors of the Connecticut Gore, stated and considered. Hudson & Goodwin (Hartford, 1802).