Murdock v. City of Memphis
Encyclopedia
Murdock v. Memphis, 87 U.S. 590
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...

 (1875), is a case decided by the United States Supreme Court
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...

.

William Tod Otto
William Tod Otto
William Tod Otto was an American judge and the eighth reporter of decisions of the United States Supreme Court, serving as reporter from 1875 to 1883.-Biography:...

 argued the case on behalf of the City of Memphis
Memphis, Tennessee
Memphis is a city in the southwestern corner of the U.S. state of Tennessee, and the county seat of Shelby County. The city is located on the 4th Chickasaw Bluff, south of the confluence of the Wolf and Mississippi rivers....

. The case having been reargued, as well as argued originally, before the appointment of the Chief Justice Waite, who took no part in the judgment.

Murdock challenged on several grounds a state court's decision relating to land devised by Murdock's ancestors. Murdock's federal claim which was outcome determinative was that a federal statute created a trust for the land. The state court rejected this claim and the Supreme Court affirmed. Murdock, however, urged the Supreme Court to review the state court's findings on state law based on the Judiciary Act of 1867. The Supreme Court interpreted the Act as not conferring jurisdiction over the state claims, but the Court did not decide as a constitutional matter whether conferring such jurisdiction would be constitutional.

The Supreme Court continued to lay some ground rules for appeals of state court decisions, namely the effect of a state court decision resting on an adequate and independent state ground
Adequate and independent state ground
The adequate and independent state ground doctrine is a doctrine of United States law governing the power of the U.S. Supreme Court to review judgments entered by state courts.- Introduction :...

. While these rules were important in the development of adequate and independent state grounds doctrine in cases like Fox Film Corp. v. Muller
Fox Film Corp. v. Muller
Fox Film Corp. v. Muller, 296 U.S. 207 , was a case in which the Supreme Court of the United States held that it cannot exert certiorari jurisdiction over a case in which there is an adequate and independent state law ground for the state court's final judgment.-Facts:Plaintiff Fox Film Corporation...

 and Michigan v. Long
Michigan v. Long
Michigan v. Long, 463 U.S. 1032 , was a decision by the United States Supreme Court that extended Terry v. Ohio, 392 U.S. 1 to allow searches of car compartments during a stop with reasonable suspicion. The case also clarified and narrowed the extent of adequate and independent state ground,...

, they were merely dicta. The Court ultimately affirmed the decision of the state court on the federal law and did not decide the two issues of state law.
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