United States Supreme Court Cases & Opinions

U.S. Supreme Court

Cory v. White, 457 U.S. 85 (1982)

Cory v. White

No. 80-1556

Argued January 18, 1982

Decided June 14, 1982

457 U.S. 85

Syllabus

Both Texas and California assert the right to levy state death taxes on the estate of Howard Hughes, the taxing officials of each State claiming that Hughes was domiciled in their State at the time of his death. The administrator of the estate filed an action in Federal District Court under the Federal Interpleader Act, alleging that the respective state officials were seeking to tax the estate on the basis of inconsistent claims. The District Court dismissed the action for lack of subject matter jurisdiction because of the failure to satisfy the Act's requirement that there be diversity of citizenship between at least two adverse parties. The Court of Appeals reversed, holding that the requisite diversity was present between the administrator and the County Treasurer of Los Angeles County. The court rejected the State's claim that, although the suit was nominally against state officials, it was in effect a suit against two sovereign States barred by the Eleventh Amendment.

Held: The Eleventh Amendment bars the statutory interpleader action. Worcester County Trust Co. v. Riley, 302 U. S. 292. Contrary to the Court of Appeals' view, Edelman v. Jordan, 415 U. S. 651, did not overrule Worcester County Trust Co. Pp. 457 U. S. 89-91.

629 F.2d 397, reversed.

WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACKMUN, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., filed an opinion concurring in the judgment, post, p. 457 U. S. 91. POWELL, J., filed a dissenting opinion, in which MARSHALL and STEVENS, JJ., joined, post, p. 457 U. S. 92.

Page 457 U. S. 86