Mississippi v. Louisiana
Annotate this Case
506 U.S. 73 (1992)
OCTOBER TERM, 1992
MISSISSIPPI ET AL. v. LOUISIANA ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
No. 91-1158. Argued November 9, 1992-Decided December 14,1992
After private plaintiffs brought suit against private defendants in the District Court to quiet title to certain land riparian to the Mississippi River, Louisiana intervened in the action and filed a third-party complaint against Mississippi seeking to determine the boundary between the two States in the vicinity of the disputed land. Following this Court's denial of leave to Louisiana to file a bill of complaint against Mississippi in this Court, the District Court found the land in question to be part of Mississippi and quieted title in the plaintiffs. The Court of Appeals reversed.
Held: The uncompromising language of 28 U. S. C. § 1251(a), which gives to this Court "original and exclusive jurisdiction of all controversies between two or more States" (emphasis added), deprived the District Court of jurisdiction over Louisiana's third-party complaint against Mississippi. Though § 1251(a) is phrased in terms of a grant of jurisdiction to this Court, the plain meaning of "exclusive" necessarily denies jurisdiction of such cases to any other federal court. See, e. g., California v. Arizona, 440 U. S. 59, 63. The District Court's adjudication of a private action involving the location of the boundary between two States does not violate § 1251(a), since that section speaks in terms of parties, not claims or issues. But the adjudication of such an action would not be binding on the States in any way. Because both of the courts below intermixed the questions of title to real property and of the state boundary's location, it must be determined on remand whether on this record the claims of title may fairly be decided without additional proceedings in the District Court. pp. 75-79.
937 F.2d 247, reversed and remanded.
REHNQUIST, C. J., delivered the opinion for a unanimous Court.
James W McCartney argued the cause for petitioners.
With him on the briefs were Robert R. Bailess, Charles Alan Wright, Mike Moore, Robert E. Sanders, and Richard H. Page.
Gary L. Keyser, Assistant Attorney General of Louisiana, argued the cause for respondents. With him on the brief were Richard P. Ieyoub, Attorney General of Louisiana, and E. Kay Kirkpatrick, Assistant Attorney General.
CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.
This action was originally commenced by private plaintiffs suing other private defendants in the District Court for the Southern District of Mississippi to quiet title to certain land riparian to the Mississippi River. The State of Louisiana intervened in the action and filed a third-party complaint against the State of Mississippi seeking to determine the boundary between the two States in the vicinity of the disputed land. We hold that 28 U. S. C. § 1251(a), granting to this Court original and exclusive jurisdiction of all controversies between two States, deprived the District Court of jurisdiction of Louisiana's third-party complaint against Mississippi.
The land in question lies along the west bank of the Mississippi River near Lake Providence, Louisiana. The private plaintiffs, known as the Houston Group, alleged that they own the land in fee simple as a result of a homestead patent issued by the United States in 1888 and a deed issued by Mississippi in 1933. Louisiana and the Lake Providence Port Commission intervened in the title dispute and filed a third-party complaint against Mississippi seeking a determination of the boundary between the States. Louisiana then sought leave to file a bill of complaint against Mississippi in this Court. Mississippi opposed the motion in view of the pendency of the District Court action, and also emphasized that the case was originally a dispute between private parties: "Houston brought the suit to establish the boundary line to their land. It is incidental that the boundary line is also alleged to be the State line." App. to Pet. for Cert. 86a.