Kuhn v. Fairmont Coal Co. - 215 U.S. 349 (1910)
U.S. Supreme Court
Kuhn v. Fairmont Coal Co., 215 U.S. 349 (1910)
Kuhn v. Fairmont Coal Company
Argued December 3, 6, 1909
Decided January 3, 1910
215 U.S. 349
When administering state laws and determining rights accruing thereunder, the jurisdiction of the federal court is an independent one, coordinate and concurrent with, and not subordinate to, the jurisdiction of the state courts.
Rules of law relating to real estate, so established by state decisions rendered before the rights of the parties accrued as to have become rules of property and action, are accepted by the federal court, but where the law has not thus been settled, it is the right and duty of the federal court to exercise its own judgment, as it always does in cases depending on doctrines of commercial law and general jurisprudence.
Even in questions in which the federal court exercises its own judgment, the federal court should, for the sake of comity and to avoid confusion, lean to agreement with the state court if the question is balanced with doubt.
When determining the effect of conveyances or written instruments between private parties, citizens of different states, it is the right and duty of the federal court to exercise its own independent judgment where no authoritative state decision had been rendered by the state court before the rights of the parties had accrued and become final.
The federal court is not bound by a decision of the state court, rendered after the deed involved in the case in the federal court was made and after the injury was sustained, holding that there is no implied reservation in a deed conveying subsurface coal and the right to mine it to leave enough coal to support the surface in its original position.
The facts are stated in the opinion.