ArtIII.S1.6.6 Limits on State Court Control of Federal Proceedings

Article III, Section 1:

The judicial Power of the United States, shall be vested in one supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish. The Judges, both of the supreme and inferior Courts, shall hold their Offices during good Behaviour, and shall, at stated Times, receive for their Services, a Compensation, which shall not be diminished during their Continuance in Office.

State courts have limited authority to issue orders that would affect the federal courts.1 For instance, state courts cannot prevent the effectuation of federal court judgments.2 Nor do state courts have the power to issue writs of habeas corpus ordering the release of persons in federal custody or writs of mandamus requiring action by federal officials.3

In addition, state courts generally lack the power to enjoin federal court proceedings.4 One exception to that rule occurs in cases in which a state court has custody of property subject to proceedings in rem or quasi in rem:5 in such cases, where the state court has exclusive jurisdiction to proceed, it may enjoin the parties from further action in federal court.6

By contrast, federal courts may under certain circumstances enjoin actions in state courts. See ArtIII.S1.6.7 Federal Non-Interference with State Jurisdiction and Abstention. back
McKim v. Voorhies, 11 U.S. 279, 281 (1812) ( “the State Court had no jurisdiction to enjoin a judgment of the Circuit Court of the United States” ). Cf. Riggs v. Johnson County, 73 U.S. 166, 195–96 (1868). back
Ableman v. Booth, 62 U.S. (21 How.) 506, 523 (1859) (when a prisoner is in federal custody, “neither the writ of habeas corpus, nor any other process issued under State authority, can pass over the line of division between the two sovereignties” ); Tarble’s Case, 80 U.S. 397 (1872); McClung v. Sillman, 19 U.S. 598 (1821) (holding that a state court could not issue a writ of mandamus to an officer of the United States). back
Donovan v. City of Dallas, 377 U.S. 408 (1964); Gen. Atomic Co. v. Felter, 434 U.S. 12 (1977) (per curiam). back
In rem and quasi in rem proceedings involve the determination of property rights with respect to a thing within the court’s jurisdiction. See In Rem, Black’s Law Dictionary (11th ed. 2019). back
Princess Lida v. Thompson, 305 U.S. 456 (1939). back