Peters v. Broward - 222 U.S. 483 (1912)
U.S. Supreme Court
Peters v. Broward, 222 U.S. 483 (1912)
Peters v. Broward
Argued November 8, 1911
Decided January 9, 1912
222 U.S. 483
Under the law of Florida, as declared by its highest court, where there is a variance between the title of a bill as enrolled and promulgated and the title of the act as shown by the journals, the latter will control.
While the judgment of the highest court of the state in a case may not be res judicata of the case at bar, the parties and land affected not being the same, if in deciding it the court announces what the law of the state is and whether a particular statute was or was not validly enacted under the state constitution, this Court will follow it as an authoritative announcement of the law of the state.
Whether a particular state law has been passed by the legislature in such manner as to become a valid law under the state constitution is a state, and not a federal, question, and federal courts must follow the adjudications of the state court.
Although the decision of the state court holding a particular law to be unconstitutional may not have been rendered until after rights based thereon had arisen, if the highest court simply followed a rule laid down before such rights had arisen, the decision in the later case is binding upon the federal courts.
Where the state courts have held that the journals of the legislature can be examined to determine whether an act has been validly passed, it is the duty of one proposing to rely upon the act to examine the journals, and he cannot plead ignorance of the law as an excuse for not doing so.
This Court cannot hold that an act is constitutional under the state law because the defect on which the state court declared it to be unconstitutional occurred through mistake, when the state court has passed on that question and held the act unconstitutional even under such condition.
Although the case may be a hard one, those who expend money on the faith of an invalid act cannot obtain redress from the courts, but must apply to the legislature.
An act of the State of Florida incorporating a railroad company and granting it aid having been held unconstitutional by the highest court of that state because the journal showed that it was an act to incorporate only, and only one subject can be embraced in one act, the federal courts are bound to follow that decision, and to hold that Trustees of the Internal Improvement Fund had no power to convey land under that act, and that the grantees have no title to any of the land claimed thereunder.
The facts, which involve the title to land in Florida under an act of the legislature of that state, are stated in the opinion.