James McBride in Error v. The Lessee of William Hoey

Citations: 36 U.S. 167; 9 L. Ed. 673; 11 Pet. 167; 1837 U.S. LEXIS 171

Court: Supreme Court of the United States; February 11, 1837; Federal Supreme Court; Federal Appellate Court

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James McBride, the defendant, appealed a judgment from the Supreme Court of Pennsylvania affirming a verdict against him in an ejectment action initiated by William Hoey's lessee. The case arose from a dispute over a tract of land in Mercer County, where Hoey had legally acquired the property through a tax sale under Pennsylvania law, which allows owners of unseated lands to redeem them within two years of sale by paying the owed taxes plus a 25% penalty. McBride claimed that his landlord, William Clarke, had redeemed the land based on a deed from a U.S. tax collector, asserting that Clarke was the rightful owner because the land had previously been sold for unpaid federal taxes. However, Hoey’s evidence demonstrated that the land had never been legally assessed for federal taxes, rendering Clarke's deed invalid. The jury was instructed that Hoey’s lawful purchase at the tax sale could not be undermined by McBride's invalid claim of title based on the defective deed. Thus, the court concluded that an invalid title could not challenge a valid one.

Counsel for the defendant moved to dismiss the writ of error due to a lack of jurisdiction in the court. The plaintiff argued that regardless of the merits of Mr. Clarke's title, he had a prima facie interest in the property under U.S. laws, warranting recognition by the county treasurer until his title's validity was judicially questioned. The plaintiff maintained that, despite any defects in his title against the original proprietor, he had a legitimate interest to protect by paying state taxes, and he was obligated to safeguard both his interests and those of the original owner. The plaintiff contended that the case involved the interpretation of U.S. statutes and authority, which were central to the judgment by the Pennsylvania Supreme Court that denied the validity of his claims. In contrast, the defendants argued that the case did not involve federal jurisdiction, as the Pennsylvania courts only considered whether the plaintiff had a valid title that could supersede the state-derived title, which the plaintiff himself admitted was invalid. The core issue was whether Clarke could redeem the land based on an acknowledged void deed, a matter deemed appropriate solely for Pennsylvania courts. The defendants emphasized that the jurisdiction claim was insufficient, as the only question was about Clarke's right to redeem based on a void deed, irrelevant to federal statutes unless there were parties from different states involved. The principles governing jurisdiction were previously established in Crowell v. Randell.

The court reviewed prior decisions on similar legal questions, focusing on a case reported in 2 Watts 436 involving an appeal to the Pennsylvania Supreme Court. The jurisdiction of this court on a writ of error requires that an act of Congress be questioned and misinterpreted, which was not the case here. The plaintiff in error did not invoke any Congressional act in lower courts, which treated the matter as a Pennsylvania issue concerning state tax statutes. Anthony, opposing a motion, argued that the plaintiff's title derived from a Congressional act and that the tax sale violated this law, asserting the right to redeem the land based on possession and a deed. The court considered if the plaintiff had a right to redeem rather than hold the land. The case involved William Hoey, who claimed land through a tax deed and sought to redeem it after paying state taxes. Despite the defendant's acknowledgment that the federal tax sale was invalid, he argued that possession under the deed sufficed to redeem the land according to Pennsylvania law. The court of common pleas ruled in favor of the plaintiff, and this was upheld by the Pennsylvania Supreme Court upon appeal.

The case revolves around a question of Pennsylvania state law regarding whether an individual possessing land under a seemingly valid deed, which is ultimately inoperative and invalid, has the right to redeem the land after it has been sold for unpaid state taxes. The Pennsylvania state court ruled against the plaintiff in error on this matter. It was noted that the plaintiff admitted the validity of the sale conducted by the U.S. collector was not supported by federal law and acknowledged the invalidity of his deed. The court clarified that it did not address any issues regarding the federal act or the authority derived from it. Consequently, since the case was solely based on state law, the higher court lacked the jurisdiction to review the state court’s decision, leading to the dismissal of the writ of error.