California v. Texas - 457 U.S. 164 (1982)
U.S. Supreme Court
California v. Texas, 457 U.S. 164 (1982)
California v. Texas
No. 88, Orig.
Decided June 14, 1982
457 U.S. 164
Held: California's motion for leave to file a bill of complaint seeking determination of whether Howard Hughes was domiciled in California or Texas at the time of his death is granted.
(a) The bill of complaint states a "controversy" between two States within this Court's exclusive jurisdiction under 28 U.S.C. § 1251(a). California and Texas are undeniably adversaries in this action, since each State's authority to impose a death tax on the intangibles owned by a decedent depends on the decedent's having been a domiciliary of that State, and it is the law of each State that an individual has but one domicile. Thus, the outcome of this action will determine which State is entitled to levy death taxes on the Hughes estate. Moreover, California's allegations, although not yet proved, indicating that the estate was insufficient to satisfy the total amount of potential death tax claims by both States, are sufficient under Texas v. Florida, 306 U. S. 398, to characterize this case as a "controversy" between two States for purposes of § 1251(a).
(b) It is appropriate that this Court exercise its jurisdiction in this case. When California's previous motion for leave to file its complaint was denied, 437 U. S. 437 U.S. 601, several Members of the Court suggested that the need to exercise original jurisdiction might be obviated by an action in a federal district court, under the Federal Interpleader Act, to determine Hughes' domicile. However, this Court's decision in Cory v. White, ante p. 457 U. S. 85, holds that such a statutory interpleader action cannot be brought. Thus, the precondition of nonavailability of another forum, necessary for this Court's exercise of original jurisdiction, is met.