Supreme Court of the United States

Iowa Central Railway Co. v. Iowa

160 U.S. 389 · 16 S. Ct. 344 · 1896 U.S. LEXIS 2110 · 40 L. Ed. 467

January 6, 1896 · Docket 128

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Headnotes

Generated summaries
  1. Headnote 1

    The plaintiff sought a mandamus order to compel the railroad to operate a leased portion of a road. The Iowa Supreme Court applied its summary‑process rules. The railroad argued that the Fourteenth Amendment required a jury trial, but the United States Supreme Court held the amendment does not control state procedural choices.

  2. Headnote 2

    The railroad contended that the summary‑process hearing violated its Fourteenth‑Amendment rights because it denied a jury trial. The Court held that the Constitution does not guarantee a jury in such civil actions and that the absence of a jury is not itself a due‑process violation.

  3. Headnote 3

    The United States Supreme Court emphasized that the Iowa Supreme Court’s decision to apply summary process was a question of state law. Because the railroad did not assert a federal claim in its answer, the federal courts lacked jurisdiction to review the procedural choice.

  4. Headnote 4

    The railroad’s answer and its amendments contained no allegation that the proceeding violated the Constitution. Only a later brief raised a Fourteenth‑Amendment argument, which the Court held was too late to confer federal jurisdiction.

  5. Headnote 5

    Citing Leeper v. Texas, the Court explained that when state law furnishes a regular administrative process with notice and a hearing, the constitutional due‑process clause is met, and federal courts cannot intervene merely because the process differs from federal norms.

Opinion

Mr. Justice White,

after stating, the case, delivered the opinion of the court.

The contention of the plaintiff in error is that the proceeding instituted against it in the Supreme Court of Iowa was. an action for mandamus, and that no such action could lawfully be'' brought to compel it to operate the leased portion of its road until its legal duty to do so had been previously determined by the verdict of a jury. There was no assertion that the court below had no jurisdiction over the subject-matter. Nowhere in the answer or in the amendments to the answer filed on behalf of the company was it claimed that the proceeding was violative of the Constitution of the United States, or assailed any right, title, privilege, or immunity specially set up or claimed under that Constitution. Indeed, there was no mention of any right thereunder until the filing of a brief for defendant entitled “ Defendant’s Resistance and Objection to Plaintiff’s Motion to Enter Order Prayed for in the' Petition,” in the ninth paragraph whereof it was claimed that it would be a violation of the Fourteenth Amendment of the Constitution of the United States to grant the order prayed for upon the motion in question. It is apparent that this defence nierely asserted that the rights of the corporation as a citizen of the United States would be impaired by enforcing the claim urged against it on the motion, instead of by another and less summary form of action. But it is clear that the Fourteenth Amendment in no way undertakes to control the power of a State to determine by what process legal rights may be asserted or legal obligations be enforced, provided the method of procedure adopted for these purposes gives reasonable notice and affords fair opportunity to be heard before the issues are decided. This being the case, it was obviously not a right, privilege, or immunity of a citizen of the United States to have a controversy in the state court prosecuted or determined by one form, of action instead of by another. It is also equally evident, provided the form sanctioned by the state law gives notice and affords an opportunity to be heard, that the mere question of whether it was by a motion of ordinary action in no way rendered the proceeding not due process of law within the constitutional meaning of those words. Whether the court of last resort of the State of Iowa properly construed its own constitution and laws in determining that the summary process under those laws was applicable to the matter which it adjudged, was purely the decision' of a question of state law, binding upon this court. Mere irregularities in the procedure, if any, were matters solely for the consideration of the judicial tribunal within the State empowered by the laws of the State to review and correct errors committed by its courts. Such errors affect merely matters of state law and practice, in no way depending upon the Constitution of the United States or upon any act of Congress. Ludeling v. Chaffe, 143 U. S. 301, 305.

As said by this court, speaking through Mr. Chief Justice Fuller, in Leeper v. Texas, 139 U. S. 462, 468: “ Law in its regular course of administration through courts of justice is due process, and when secured by the law of the State the constitutional-requirement is satisfied.” There'was a “regular course of administration ” in the case at bar, as that term was employed in the case cited.

It is manifest that it was never contemplated by the framers of the Constitution that this court should sit in review, as an appellate court, of such a question as that presented by the record in the case at bar, viz., whether or not the highest court of a State erred in holding that it could rightfully determine from the statements in the pleadings filed by both parties to a controversy pending before it that the averments of an answer set forth no defence to the claim of the plaintiff.

It was not a denial of a right protected by the Constitution of the United States to refuse a jury trial, even though it were clearly erroneous to construe the laws of the State as justifying the refusal. Brooks v. Missouri, 124 U. S. 394; Spies v. Illinois, 123 U. S. 131, 166.

Writ of error dismissed for want of jurisdiction.