Fox Film Corp. v. Muller
Encyclopedia
Fox Film Corp. v. Muller, 296 U.S. 207
(1935), was a case in which the Supreme Court of the United States
held that it cannot exert certiorari
jurisdiction
over a case in which there is an adequate and independent state law ground for the state court's final judgment.
Fox Film Corporation sued defendant
Muller in the state trial court of Minnesota
, alleging that Muller had breached two contracts
to exhibit the company's motion pictures. Muller's defense was that the contract
was invalid under the Sherman Antitrust Act
. The trial court found for Muller, first determining that the contract was invalid under the Sherman Act. The Minnesota Supreme Court
affirmed, and the plaintiffs petitioned the U.S. Supreme Court for certiorari
. When it was discovered that the judgment was not final, the writ of certiorari was dismissed as improvidently granted. The case was then remanded back to the state supreme court, which framed the question on appeal as whether the arbitration clause
was severable
from the rest of the contract.
The state supreme court followed the judgment of the U.S. Supreme Court in the case of United States v. Paramount Famous Lasky Corporation, , which held that a similar contract was illegal in its entirety. The court then determined that the arbitration clause was not severable from the rest of the contract, rendering the entire agreement void.
, writing for a unanimous court, held that whether a federal question existed was irrelevant, because where there is an independent question of state law which is adequate to support the state court's judgment, the U.S. Supreme Court has no jurisdiction. The severability of a contractual clause was an issue of state law, and the invalidity of the arbitration clause had already been determined by the U.S. Supreme Court in the Paramount case. The state court's determination of the non-severability of the unlawful clause was thus adequate to render the contract invalid, and was independent of any question of federal law.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1935), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that it cannot exert certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
over a case in which there is an adequate and independent state law ground for the state court's final judgment.
Facts
PlaintiffPlaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
Fox Film Corporation sued defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
Muller in the state trial court of Minnesota
Minnesota
Minnesota is a U.S. state located in the Midwestern United States. The twelfth largest state of the U.S., it is the twenty-first most populous, with 5.3 million residents. Minnesota was carved out of the eastern half of the Minnesota Territory and admitted to the Union as the thirty-second state...
, alleging that Muller had breached two contracts
Breach of contract
Breach of contract is a legal cause of action in which a binding agreement or bargained-for exchange is not honored by one or more of the parties to the contract by non-performance or interference with the other party's performance....
to exhibit the company's motion pictures. Muller's defense was that the contract
Contract
A contract is an agreement entered into by two parties or more with the intention of creating a legal obligation, which may have elements in writing. Contracts can be made orally. The remedy for breach of contract can be "damages" or compensation of money. In equity, the remedy can be specific...
was invalid under the Sherman Antitrust Act
Sherman Antitrust Act
The Sherman Antitrust Act requires the United States federal government to investigate and pursue trusts, companies, and organizations suspected of violating the Act. It was the first Federal statute to limit cartels and monopolies, and today still forms the basis for most antitrust litigation by...
. The trial court found for Muller, first determining that the contract was invalid under the Sherman Act. The Minnesota Supreme Court
Minnesota Supreme Court
The Minnesota Supreme Court is the highest court in the U.S. state of Minnesota and consists of seven members. The court was first assembled as a three-judge panel in 1849 when Minnesota was still a territory. The first members were lawyers from outside of the region who were appointed by...
affirmed, and the plaintiffs petitioned the U.S. Supreme Court for certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
. When it was discovered that the judgment was not final, the writ of certiorari was dismissed as improvidently granted. The case was then remanded back to the state supreme court, which framed the question on appeal as whether the arbitration clause
Arbitration clause
An arbitration clause is a commonly used clause in a contract that requires the parties to resolve their disputes through an arbitration process...
was severable
Severability
In law, severability refers to a provision in a contract which states that if parts of the contract are held to be illegal or otherwise unenforceable, the remainder of the contract should still apply...
from the rest of the contract.
The state supreme court followed the judgment of the U.S. Supreme Court in the case of United States v. Paramount Famous Lasky Corporation, , which held that a similar contract was illegal in its entirety. The court then determined that the arbitration clause was not severable from the rest of the contract, rendering the entire agreement void.
Decision
The issue on appeal was whether a question of federal law was involved in the Minnesota Supreme Court's decision. Justice SutherlandGeorge Sutherland
Alexander George Sutherland was an English-born U.S. jurist and political figure. One of four appointments to the Supreme Court by President Warren G. Harding, he served as an Associate Justice of the U.S...
, writing for a unanimous court, held that whether a federal question existed was irrelevant, because where there is an independent question of state law which is adequate to support the state court's judgment, the U.S. Supreme Court has no jurisdiction. The severability of a contractual clause was an issue of state law, and the invalidity of the arbitration clause had already been determined by the U.S. Supreme Court in the Paramount case. The state court's determination of the non-severability of the unlawful clause was thus adequate to render the contract invalid, and was independent of any question of federal law.