Fox Film Corp. v. Muller, 296 U.S. 207 (1935)
The Supreme Court cannot review a state court decision that rests on an adequate and independent state law ground, even if a federal question may have been implicated.
In a breach of contract dispute, Fox Film Corp. sought damages in state court from Muller, who allegedly had breached contracts regarding the showing of Fox films. A federal court had ruled in a different case that contracts that were virtually identical to these contracts were void for violations of the Sherman Antitrust Act. Specifically, the court had found them unenforceable because of a problematic arbitration clause that it viewed as so integral to the rest of each agreement that they were invalid in their entirety. The state court dismissed the claim on this basis, and the higher state courts agreed. Fox appealed on the basis that the case partially involved issues of state law.Opinions
- George Sutherland (Author)
- Charles Evans Hughes
- Willis Van Devanter
- James Clark McReynolds
- Louis Dembitz Brandeis
- Pierce Butler
- Harlan Fiske Stone
- Owen Josephus Roberts
- Benjamin Nathan Cardozo
This case was resolved when the state court determined that the invalid contract provisions could not be separated from the rest of the contract. Even if any federal questions remained, resolving them would not change the outcome of the case. While a federal court may have jurisdiction if state and federal issues are inextricably intertwined, they were clearly separate in this case, so no jurisdiction exists.Case Commentary
Like the federal legislative system, the federal judiciary system is believed to be intended as a separate structure from its state counterpart, which makes federal courts reluctant to interfere with decisions at the state level. This view balances the need for nationwide consistency against the importance of allowing differences among diverse states and regions.
U.S. Supreme CourtFox Film Corp. v. Muller, 296 U.S. 207 (1935)
Fox Film Corp. v. Muller
Argued November 15, 1935
Decided December 9, 1935
296 U.S. 207
1. Where the judgment of a state court rests upon two grounds, one of which is federal and the other nonfederal in character, the jurisdiction of this Court fails if the nonfederal ground is independent of the federal ground and adequate to support the judgment. P. 296 U. S. 210.
2. Whether the provisions of a contract are nonseverable, so that, if one be held invalid the others must fall with it, is a question of general, and not of federal, law. P. 296 U. S. 210.
3. A ruling by a state supreme court that a concededly invalid arbitration clause in a contract between a motion picture distributor and an exhibitor (the same clause that was held invalid as a violation of the Sherman Act in Paramount Famous Corp. v. United States, 282 U. S. 30) was inseparable from the other provisions, and rendered the entire contract unenforceable, held a nonfederal ground adequate to support the judgment without regard to whether the court decided a federal question in determining the contract invalid also on another ground. P. 296 U. S. 210.
Writ of certiorari to 194 Minn. 654, 260 N.W. 320, dismissed.
Certiorari, 295 U.S. 730, to review a judgment affirming a judgment denying recovery in an action for damages for breach of contract. A writ of certiorari previously granted in this case, 293 U.S. 550, to review an earlier
judgment of the state court, 192 Minn. 212, 255 N.W. 845, was dismissed as improvidently granted, it appearing that no final Judgment had been entered, 294 U.S. 696.