Muskrat v. United States
Encyclopedia
Muskrat v. United States, 219 U.S. 346
(1911), is a case that appears in virtually every constitutional law
casebook
published, because of its delineation of the authority of United States federal courts
to hear certain kinds of cases.
to bring suits against the United States to determine the constitutionality of a law allocating tribal lands, and providing that Counsel for both sides were to be paid from the United States Treasury. Several cases were brought pursuant to this statute, including suits brought by David Muskrat and J. Henry Dick opposing the partition of Indian lands, and by another pair, William Brown and Levi B. Gritts, opposing a prohibition against the sale of certain Indian lands.
was named as a defendant
, the case in question was not an actual controversy: rather, the statute was merely devised to test the constitutionality of a certain type of legislation, and the Court's ruling would be nothing more than an advisory opinion
; therefore, it dismissed the suit for failing to present a "case or controversy
", as required by Article III of the United States Constitution.
act, which permits a party to seek a declaration of rights against another party, even where no affirmative relief (e.g. damages or an injunction) is being sought. In a declaratory judgment action, if under the facts as proved, there is some possibility of a future need for relief as among the parties, a declaratory judgment may be entered.
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...
(1911), is a case that appears in virtually every constitutional law
Constitutional law
Constitutional law is the body of law which defines the relationship of different entities within a state, namely, the executive, the legislature and the judiciary....
casebook
Casebook
A casebook is a type of textbook used primarily by students in law schools. Rather than simply laying out the legal doctrine in a particular area of study, a casebook contains excerpts from legal cases in which the law of that area was applied. It is then up to the student to analyze the language...
published, because of its delineation of the authority of United States federal courts
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
to hear certain kinds of cases.
Facts
In this case, Congress passed a statute permitting certain Native AmericansNative Americans in the United States
Native Americans in the United States are the indigenous peoples in North America within the boundaries of the present-day continental United States, parts of Alaska, and the island state of Hawaii. They are composed of numerous, distinct tribes, states, and ethnic groups, many of which survive as...
to bring suits against the United States to determine the constitutionality of a law allocating tribal lands, and providing that Counsel for both sides were to be paid from the United States Treasury. Several cases were brought pursuant to this statute, including suits brought by David Muskrat and J. Henry Dick opposing the partition of Indian lands, and by another pair, William Brown and Levi B. Gritts, opposing a prohibition against the sale of certain Indian lands.
Result
The United States Supreme Court refused to allow the case to be heard, maintaining that, though the United StatesUnited States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
was named as a 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...
, the case in question was not an actual controversy: rather, the statute was merely devised to test the constitutionality of a certain type of legislation, and the Court's ruling would be nothing more than an advisory opinion
Advisory opinion
An advisory opinion is an opinion issued by a court that does not have the effect of adjudicating a specific legal case, but merely advises on the constitutionality or interpretation of a law. Some countries have procedures by which the executive or legislative branches may certify important...
; therefore, it dismissed the suit for failing to present a "case or controversy
Case or controversy
The Case or Controversy Clause of Article III of the United States Constitution has been deemed to impose a requirement that United States federal courts are not permitted to hear cases that do not pose an actual controversy — that is, an actual dispute between adverse parties which is capable of...
", as required by Article III of the United States Constitution.
Later developments
Although this decision remains good law, its importance has been diminished by the Supreme Court's approval of the declaratory judgmentDeclaratory judgment
A declaratory judgment is a judgment of a court in a civil case which declares the rights, duties, or obligations of one or more parties in a dispute. A declaratory judgment is legally binding, but it does not order any action by a party. In this way, the declaratory judgment is like an action to...
act, which permits a party to seek a declaration of rights against another party, even where no affirmative relief (e.g. damages or an injunction) is being sought. In a declaratory judgment action, if under the facts as proved, there is some possibility of a future need for relief as among the parties, a declaratory judgment may be entered.
See also
- List of United States Supreme Court cases, volume 219
- Hayburn's CaseHayburn's CaseHayburn's Case, 2 U.S. 409 , was a case in which the Supreme Court of the United States was invited to rule on whether certain non-judicial duties could be assigned by Congress to the federal circuit courts in their official capacity. This was the first time that the Supreme Court addressed the...
, 2 U.S. 409 (1792)