| Marshall v. Holmes | |
|---|---|
 | |
| Argued April 6–7, 1891 Decided November 9, 1891 | |
| Full case name | Marshall v. Holmes et al |
| Citations | 141 U.S. 589 (more) 12 S. Ct. 62, 35 L. Ed. 870 |
| Case history | |
| Prior | 13 La.Ann. 313 (La., 1887) |
| Holding | |
| Federal courts have jurisdiction to hear actions for equitable relief from judgements in state court where there is diversity; individual judgements in multiple cases tried singly can be heard in federal court when their aggregate meets the federal amount in controversy even where none of them do by themselves, and courts may set aside or vacate judgements obtained by intrinsic fraud if letting the result stand would be unconscionable. Eighth District of Louisiana reversed | |
| Court membership | |
| |
| Case opinion | |
| Majority | Harlan, joined by unanimous |
| Laws applied | |
| Common law of civil procedure | |
Marshall v. Holmes, 141 U.S. 589, is an 1891 decision of the United States Supreme Court on equitable relief, res judicata and fraud on the court in diversity jurisdiction. Justice John Marshall Harlan wrote for a unanimous Court that held it unconscionable to allow a state court's decision to stand that had been based on documents later exposed as forgeries. It permitted a federal case seeking to set that verdict aside to go forward.
The petitioner had previously had several judgements rendered against her in Louisiana state court. After discovering that a letter attributed to her, used as evidence against her at trial, had been forged, she filed a petition for a bill of review in the Southern District of New York seeking to enjoin the respondent from endorsing the verdict. The state court would not allow the case to be removed, and so Marshall appealed directly to the Supreme Court.
Harlan's opinion considered both the question of whether federal courts had the authority to so disturb a state court's decision, and whether a court other than that which rendered the original judgement could grant equitable relief in a decided action where allegedly fraudulent evidence had been considered. He held that since Marshall had sought an independent action, Louisiana law and federal precedent allowed the case to be considered. Harlan also dismissed the respondents' argument that federal courts could not hear the case since none of the judgements against Marshall exceeded the $500 minimum then legally required by noting that they well exceeded that amount in the aggregate.
Other courts noted shortly afterwards that the invocation of unconscionability seemed to be in conflict with the Court's unanimous holding 13 years earlier in United States v. Throckmorton that equitable relief could not be granted in cases of intrinsic fraud such as that Marshall alleged. The Court was asked several years later in Graver v. Faurot to reconcile the two cases, but declined. As of the early 21st century this issue remains unresolved; some state courts and the Third Circuit Court of Appeals have held that Marshall overruled Throckmorton while others have reaffirmed the latter case.