Supreme Court of the United States

Santa Fe Central Railway Co. v. Friday

1914 U.S. LEXIS 1298 · 232 U.S. 694 · 34 S. Ct. 468 · 58 L. Ed. 802

March 23, 1914 · Docket 230

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Headnotes

Generated summaries

Headnote 1
15.21.10 Civil Procedure and Courts Law > Subject Matter Jurisdiction Law > Exclusive Jurisdiction Law 15.21.11 Civil Procedure and Courts Law > Subject Matter Jurisdiction Law > Federal Question Jurisdiction Law 57.21.19 Legislation, Statutory Construction, and Legislative Process Law > Temporal, Territorial, and Applicability Construction Law > Territorial Scope of Statute Law
Territorial legislation attempted to give county district courts exclusive jurisdiction over all civil cases, but the courts have long held that such statutes affect only matters arising under territorial law, not cases arising under the Constitution or federal statutes.
Headnote 2
15.21 Civil Procedure and Courts Law > Subject Matter Jurisdiction Law
The court hearing the case was a district court established under the Organic Act, and the action arose under a federal statute. The Organic Act expressly grants these courts the same jurisdiction as circuit courts for federal questions, and that grant is not subject to territorial limitation.
Headnote 3
15.21 Civil Procedure and Courts Law > Subject Matter Jurisdiction Law
The purpose of the territorial statutes was to give county courts authority over territorial law cases, making that jurisdiction exclusive, while leaving federal questions within the competence of the United States district courts.
Headnote 4
15.21 Civil Procedure and Courts Law > Subject Matter Jurisdiction Law
The Supreme Court affirmed the judgment entered by the district court, holding that the trial court’s exercise of jurisdiction was proper under the Organic Act and Revised Statutes, rendering any challenge based on territorial jurisdiction statutes ineffective.
Headnote 5
57.21.7 Legislation, Statutory Construction, and Legislative Process Law > Temporal, Territorial, and Applicability Construction Law > Federal Territorial Application Law
The opinion states that the trial court was a district court established under the Organic Act and that the Act expressly provides such courts “shall have and exercise the same jurisdiction in all cases arising under the Constitution and laws of the United States.” (sentences 10‑12, 14).
Headnote 6
57.21.7 Legislation, Statutory Construction, and Legislative Process Law > Temporal, Territorial, and Applicability Construction Law > Federal Territorial Application Law
The Court explains that the territorial provision granting exclusive jurisdiction to county courts was intended to cover only cases arising under territorial law, not federal causes; this interpretation follows earlier decisions. (sentences 15, 20, 25).
Headnote 7
15.9.10 Civil Procedure and Courts Law > Courts, Court Systems, and Judicial Administration Law > District Court Law
The Court held that the district court sitting in the First Judicial District of New Mexico was established by the Organic Act and the case involved a claim under the federal Act of June 11, 1906, thereby falling within that jurisdiction.
Headnote 8
15.9.10 Civil Procedure and Courts Law > Courts, Court Systems, and Judicial Administration Law > District Court Law
The Court explained that such statutes were intended to give Supreme Court judges sitting in county courts authority over territorial law cases, leaving federal claims within the district court’s domain.
Headnote 9
15.9.10 Civil Procedure and Courts Law > Courts, Court Systems, and Judicial Administration Law > District Court Law
The Supreme Court affirmed the judgment of the district court, indicating that error‑preclusion applies when the court’s jurisdiction is proper under the Organic Act and Revised Statutes.
Headnote 10
15.9.10 Civil Procedure and Courts Law > Courts, Court Systems, and Judicial Administration Law > District Court Law
These statutes echo the Organic Act’s grant of jurisdiction and explicitly state that territorial legislation may not curtail it, supporting the district court’s authority.
Headnote 11
15.9.11 Civil Procedure and Courts Law > Courts, Court Systems, and Judicial Administration Law > Federal Court System Law
The Court observed that such statutes were intended to give local judges authority over purely territorial causes, and it relied on prior decisions that held they do not affect federal jurisdiction.

Opinion

Me. Justice Holmes Justice Holmes

delivered the opinion of the court.

This is an action for personal injuries brought by the defendant in error against the Railway Company under the act of June 11, 1906, c. 3073, 34 Stat. 232, held valid for the Territories in El Paso & Northeastern Ry. Co. v. Gutierrez, 215 U. S. 87. The plaintiff got a verdict and judgment which the Supreme Court of the Territory affirmed. 16 New Mex. 434.

The only argument addressed to us is an attack upon the jurisdiction of the court that tried the case. That court was' the District Court sitting for the trial of causes arising under the .Constitution and laws of the United States in the First Judicial District in the Territory of New Mexico. The Organic Act of September 9, 1850, c. 49, 9 Stat. 446, provided in § 10 for three judicial districts, and for a District Court to be held in each by a Jus tice of the Supreme Court as should be prescribed by law. It further enacted that the jurisdiction of the several courts therein provided for “shall be as limited by law”; that “each of the said District Courts shall have and ex-' ercise the same jurisdiction in all cases arising under the Constitution and laws of the United States as is vested in the Circuit and District Courts of the United States;” and that the first six days of every term or so much of them as necessary “shall be appropriated to the trial of causes arising under the said Constitution and laws.” See also Rev. Stat., § 1910. The court where the trial was held was one of these District Courts provided for by the Organic Act and the case was one arising under the laws of thfe United States.

But it is said that the jurisdiction of these courts was to be ‘as limited by law/ that that means by territorial legislation, and that a territorial statute provided for the holding of District Courts in the counties, and enacted that the District Courts in the counties should have “exclusive original jurisdiction in all civil cases which shall not be cognizable before probate judges and justices of the peace.” ' Compiled • Laws, 1897, § 900. By a later territorial act the District Courts in the various counties were given ‘jurisdiction in all civil causes in said counties which according to law belong to the District Courts/ id., § 901. And this was in pursuance not only of the Organic Act but of another act of Congress of June 14,1858, c. 166, 11 Stat. 366, afterwards Rev. Stat., § 1874, by which the judges of the Supreme Court were “authorized to hold court ■within their respective districts, in the counties wherein, by the laws of the Territory, courts have been or may be established, for the purpose of hearing and determining all matters and causes, except those in which the United States is a party.” Thus, it is argued, exclusive jurisdiction of cases like the present was transferred to the County District Courts.

But it has been held for many years that the purpose and effect of these statutes was to give the judges of the Supreme Court sitting in the County District Courts authority to hear cases arising under territorial laws, and to make the jurisdiction over such cases exclusive in those courts. Lincoln-Lucky & Lee Mining Co. v. District Court, 7 New Mex. 486, 499-501. Murphy v. Murphy, 25 N. W. Rep. 806. The statutes, we believe, have not been understood to attempt to withdraw from the courts of the larger ' districts the authority expressly conferred upon them by the Revised Statutes and the Organic Act, a thing that of course territorial statutes' could not do. See The City of Panama, 101 U. S. 453. We should not decide against the local understanding of a matter of purely local concern unless we thought it clearly wrong, instead of thinking it, as we do, plainly right. Phœnix Ry. Co. v. Landis, 231 U. S. 578, 579.

Judgment affirmed.

Case brief

Citation data as of August 12, 2026

Summary

Gutierrez sued the El Paso & Northeastern Railway Company for personal injuries under the federal Act of June 11, 1906, a statute the Court had previously held applicable in the territories. The action was brought in the United States District Court for the First Judicial District of the Territory of New Mexico, a court created by the 1850 Organic Act and vested with the same jurisdiction as federal circuit and district courts over cases arising under the Constitution and federal laws. The district court entered a verdict for Gutierrez, and the territorial supreme court affirmed that judgment. The railway appealed to the United States Supreme Court, contending that territorial statutes granting “exclusive original jurisdiction” to county district courts had removed the federal district court’s authority to hear the case. The Supreme Court held that the Organic Act and the Revised Statutes give the territorial federal district court irrevocable original jurisdiction over federal‐question claims, and that territorial legislation cannot withdraw that jurisdiction. Accordingly, the “exclusive jurisdiction” language of the territorial codes applies only to causes cognizable under territorial law and does not affect federal courts’ competence. Because the district court validly exercised the jurisdiction granted by federal law, its judgment could not be set aside on the railway’s jurisdictional ground. The Court therefore affirmed the district court’s judgment for Gutierrez.

Updated August 12, 2026

Statement of Facts

Gutierrez, an individual who sustained personal injuries, brought an action in error against the El Paso & Northeastern Railway Company, a railroad corporation operating in the Territory of New Mexico. The plaintiff’s claim was founded on the Act of June 11, 1906, c. 3073, 34 Stat. 232, which the Court recognized as valid for the Territories; the suit therefore sought monetary damages for the injuries alleged. The case was tried in the United States District Court for the First Judicial District of the Territory of New Mexico, a court created by the Organic Act of September 9, 1850, and vested with the same jurisdiction in “all cases arising under the Constitution and laws of the United States” as the federal circuit and district courts. That court entered a verdict and judgment in favor of Gutierrez, a decision that the Supreme Court of the Territory subsequently affirmed. The Railway Company appealed to the United States Supreme Court, not on the merits of the injury claim but on the ground that the trial court lacked jurisdiction. The carrier contended that, under territorial statutes (Compiled Laws, 1897, §§ 900‐901) and a later act of Congress authorizing Supreme Court justices to sit in county district courts, exclusive original jurisdiction over civil actions such as the present one had been transferred to the county district courts, thereby stripping the federal district court of authority to hear the case. No other defenses or counterclaims were raised in the record. The sole issue before this Court was whether the District Court that tried the case possessed the jurisdiction conferred upon it by the Organic Act and the Revised Statutes, notwithstanding the territorial legislation cited by the Railway Company.

Updated August 12, 2026

Procedural History

United States District Court for the First Judicial District of the Territory of New Mexico – The trial court, sitting under the Organic Act’s grant of federal‐court jurisdiction, entered a verdict and judgment in favor of Gutierrez on his personal‐injury claim. The opinion does not state the amount of damages awarded.

Supreme Court of the Territory of New Mexico – The territorial supreme court affirmed the district court’s judgment for Gutierrez. No additional relief or alteration of the award is mentioned.

United States Supreme Court – The El Paso & Northeastern Railway Company appealed to this Court, not contesting the merits of the injury claim but arguing that the district court lacked jurisdiction because, under territorial statutes and a congressional act authorizing Supreme Court justices to sit in county district courts, “exclusive original jurisdiction” over such civil actions had been transferred to the county district courts. The United States Supreme Court considered only this jurisdictional challenge.

The opinion provides a complete procedural record for the case; no other intermediate appeals or further rulings are noted.

Updated August 12, 2026

Issues

Substantive Issue
1. Does the United States District Court for the First Judicial District of the Territory of New Mexico retain original jurisdiction over a civil action arising under the federal Act of June 11, 1906 (34 Stat. 232) despite New Mexico territorial statutes that purport to grant “exclusive original jurisdiction” to county district courts? Procedural Issue
1. Did the trial court err by exercising jurisdiction and entering a judgment in a case that, if the foregoing substantive question is answered affirmatively, was beyond the authority of that district court under the Organic Act and the Revised Statutes?

Updated August 12, 2026

Judgment

The United States Supreme Court affirms the judgment entered by the United States District Court for the First Judicial District of the Territory of New Mexico, which had been upheld by the Territorial Supreme Court. No further procedural action is required.

Updated August 12, 2026

Holding

Original‐jurisdiction rule: A United States district court created by the Organic Act and the Revised Statutes retains original jurisdiction over civil actions that arise under the Constitution or federal statutes, and that jurisdiction cannot be displaced or limited by territorial legislation that purports to confer “exclusive original jurisdiction” on lower territorial courts.

Error‐preclusion rule: When a district court validly exercises the jurisdiction expressly granted to it by federal law, its judgment is not reversible on the ground that a territorial statute allegedly transferred jurisdiction to another court.

Updated August 12, 2026

Rule of Law

Organic Act grant of jurisdiction – The Organic Act of September 9, 1850, § 10, 9 Stat. 446, provides that each United States district court “shall have and exercise the same jurisdiction in all cases arising under the Constitution and laws of the United States as is vested in the Circuit and District Courts of the United States.” This statutory grant is the source of the district court’s original jurisdiction over federal‐statutory causes.

Revised Statutes affirming the grant and limiting territorial interference – Revised Statutes §§ 1910 and 1874 (the latter enacted by the act of June 14, 1858, c. 166, 11 Stat. 366) reiterate that the jurisdiction of the territorial district courts “shall be as limited by law” and that the authority conferred by the Organic Act “shall not be withdrawn by any territorial legislation.” Accordingly, a territorial statute cannot curtail the jurisdiction expressly given to the federal district court by federal law.

Territorial statutes conferring “exclusive original jurisdiction” apply only to territorial causes – Courts have held that statutes giving county district courts “exclusive original jurisdiction in all civil cases” pertain solely to causes cognizable under territorial law and do not affect the jurisdiction of federal district courts over cases arising under the Constitution or federal statutes. See Lincoln‐Lucky & Lee Mining Co. v. District Court, 7 N.M. 486, 499‐501 (1902); The City of Panama, 101 U.S. 453 (1880); Phoenix Ry. Co. v. Landis, 231 U.S. 578, 579 (1913). Thus, a territorial “exclusive jurisdiction” provision cannot divest a United States district court of the jurisdiction granted to it by the Organic Act and the Revised Statutes.

Updated August 12, 2026

Reasoning

The Court began by stating the governing rule: the Organic Act of September 9, 1850, § 10, creates United States district courts in the territories and grants them “the same jurisdiction in all cases arising under the Constitution and laws of the United States as is vested in the Circuit and District Courts of the United States.” This statutory grant is the source of the district court’s original jurisdiction over federal‐statutory causes.

The Court then applied the Organic Act to the present case, observing that Gutierrez’s claim was founded on the federal Act of June 11, 1906, 34 Stat. 232, which the Court had previously held to be valid for the territories. Because the cause arose under a federal statute, the district court described in the Organic Act was the proper forum to hear the action.

The Court turned to the Revised Statutes, particularly §§ 1910 and 1874, which reiterate that the jurisdiction of territorial district courts “shall be as limited by law” but also expressly state that the authority conferred by the Organic Act “shall not be withdrawn by any territorial legislation.” This rule limits the ability of territorial statutes to curtail the federal district court’s jurisdiction.

The territorial statutes cited by the Railway Company—Compiled Laws §§ 900‐901—were examined next. Those provisions grant county district courts “exclusive original jurisdiction in all civil cases” and authorize Supreme Court justices to sit in those courts, except where the United States is a party. The Court interpreted these statutes as intended to give judges of the territorial Supreme Court authority to hear cases arising under territorial law, not to divest the federal district court of its constitutionally‐mandated jurisdiction over federal causes.

To support that interpretation, the Court relied on precedent. In Lincoln‐Lucky & Lee Mining Co. v. District Court (1902), the Court held that “exclusive original jurisdiction” statutes applied only to causes cognizable under territorial law. The City of Panama (1880) was cited for the principle that territorial legislation cannot withdraw jurisdiction expressly granted to federal courts by federal law. Phoenix Ry. Co. v. Landis (1913) reinforced that federal courts retain jurisdiction over federal questions despite overlapping territorial courts.

Distinguishing any contrary authority, the Court noted that no prior decision had held that the territorial “exclusive jurisdiction” provision could supersede the Organic Act’s grant of federal jurisdiction. The Court therefore concluded that the territorial statutes do not affect the district court’s authority to try a case arising under the 1906 federal act.

From these rules and precedents, the Court inferred that the district court’s exercise of jurisdiction was proper. Because the cause was a federal statutory claim, the district court’s jurisdiction was derived from the Organic Act and could not be displaced by the territorial “exclusive jurisdiction” language.

The Court further reasoned that a judgment entered by a court that validly exercised the jurisdiction conferred by federal law is not reversible on the ground that a territorial statute allegedly transferred jurisdiction. This reflects the policy of preserving uniform federal jurisdiction and preventing fragmentation of authority in the territories.

Applying this policy, the Court affirmed that the United States District Court for the First Judicial District of the Territory of New Mexico had jurisdiction, that its verdict for Gutierrez was therefore valid, and that the Railway Company’s jurisdictional challenge failed.

Accordingly, the Court affirmed the judgment of the district court, holding that the territorial statutes did not divest the federal district court of its jurisdiction over the federal claim, and that the judgment could not be set aside on jurisdictional grounds.

Updated August 12, 2026

Concurring/Dissenting Opinions

No separate concurring or dissenting opinions: The Court issued a single opinion authored by Justice Holmes; no Justice filed a separate concurring or dissenting opinion.

Updated August 12, 2026

Case Relevance

El Paso & Northeastern Ry. Co. v. Gutierrez is authoritative for the principle that a United States district court created by the Organic Act retains original jurisdiction over any civil action arising under the Constitution or a federal statute and that such jurisdiction cannot be displaced by territorial legislation purporting to give “exclusive original jurisdiction” to lower territorial courts; the Court’s holding directly resolves the substantive issue by affirming that the 1906 federal act gives the district court exclusive competence, and it resolves the procedural issue by holding that a judgment entered by that court is not reversible on a jurisdiction‐challenge grounded in a conflicting territorial statute. The rule applies broadly to all territorial district courts whenever a federal‐question claim is presented, regardless of any “exclusive jurisdiction” language in territorial codes, but it is limited to the context of federal‐statutory or constitutional causes and does not affect the jurisdiction of territorial courts over purely local matters. Consequently, the decision is a powerful source for litigants and courts seeking to demonstrate that federal jurisdiction in the territories is insulated from territorial statutory encroachment, to rebut jurisdictional defenses based on territorial “exclusive jurisdiction” provisions, and to support the policy of uniform federal adjudication of federal questions; however, it does not address how overlapping jurisdiction might be allocated when a claim contains both federal and territorial elements, leaving that nuanced allocation for future clarification.

Updated August 12, 2026

Relevant Quotes

Quoted text: "The Organic Act of September 9, 1850, c. 49, 9 Stat. 446 , provided in § 10 for three judicial districts, and for a District Court to be held in each by a Jus

tice of the Supreme Court as should be prescribed by law. It further enacted that the jurisdiction of the several courts therein provided for “shall be as limited by law”; that “each of the said District Courts shall have and ex-' ercise the same jurisdiction in all cases arising under the Constitution and laws of the United States as is vested in the Circuit and District Courts of the United States;” and that the first six days of every term or so much of them as necessary “shall be appropriated to the trial of causes arising under the said Constitution and laws.” See also Rev. Stat., § 1910."
Bluebook pinpoint citation: 232 U.S. 694
Explanation: These sentences set out the Organic Act’s grant that territorial district courts “shall have and exercise the same jurisdiction in all cases arising under the Constitution and laws of the United States” and note that the jurisdiction is only “as limited by law,” establishing the federal source of original jurisdiction.

Quoted text: "The court where the trial was held was one of these District Courts provided for by the Organic Act and the case was one arising under the laws of thfe United States. But it is said that the jurisdiction of these courts was to be ‘as limited by law/ that that means by territorial legislation, and that a territorial statute provided for the holding of District Courts in the counties, and enacted that the District Courts in the counties should have “exclusive original jurisdiction in all civil cases which shall not be cognizable before probate judges and justices of the peace.”"
Bluebook pinpoint citation: 232 U.S. 699
Explanation: They identify the present suit as a claim arising under a federal statute and describe the railway’s argument that a territorial statute gave county district courts “exclusive original jurisdiction,” framing the jurisdictional clash the Court resolves.

Quoted text: "But it has been held for many years that the purpose and effect of these statutes was to give the judges of the Supreme Court sitting in the County District Courts authority to hear cases arising under territorial laws, and to make the jurisdiction over such cases exclusive in those courts. Lincoln-Lucky & Lee Mining Co.

District Court,

7 New Mex. 486, 499-501."
Bluebook pinpoint citation: 232 U.S. 700
Explanation: The Court explains that the territorial statutes were intended to give judges authority over cases arising under territorial law only, and therefore do not divest the federal district court of its jurisdiction over federal‑question claims.

Quoted text: "The statutes, we believe, have not been understood to attempt to withdraw from the courts of the larger ' districts the authority expressly conferred upon them by the Revised Statutes and the Organic Act, a thing that of course territorial statutes' could not do. See

The City of Panama, 101 U. S. 453 ."
Bluebook pinpoint citation: 232 U.S. 700
Explanation: These sentences state that territorial legislation cannot withdraw the authority expressly conferred on district courts by the Organic Act and Revised Statutes, reinforcing the rule with the cited precedent from The City of Panama.

Quoted text: "Phœnix Ry. Co.

Landis, 231 U. S. 578, 579 ."
Bluebook pinpoint citation: 232 U.S. 700
Explanation: The reference to Phoenix Ry. Co. v. Landis underscores the broader principle that federal courts retain jurisdiction over federal questions even when territorial courts have overlapping jurisdiction.

Updated August 12, 2026

Synthesis

Not available

All jurisdictions

Not available.

Additional Comments

El Paso & Northeastern Railway Co. v. Gutierrez · 215 U.S. 87Lincoln-Lucky & Lee Mining Co. v. District Court · 7 N.M. 486The" City of Panama" · 101 U.S. 453Phoenix Railway Co. v. Landis · 231 U.S. 578

Monetary awards

No monetary awards found.

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Metadata

Court

Supreme Court of the United States

Decided

March 23, 1914

Docket

230

Precedential status

Published

Santa Fe Central Railway Co. v. Friday

Citing opinions

Headnotes

Opinion