James Stewart & Co. v. Sadrakula

309 U.S. 94, 60 S. Ct. 431, 84 L. Ed. 596, 1940 U.S. LEXIS 1066, 127 A.L.R. 821
CourtSupreme Court of the United States
DecidedJanuary 29, 1940
Docket251
StatusPublished
Cited by231 cases

This text of 309 U.S. 94 (James Stewart & Co. v. Sadrakula) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Stewart & Co. v. Sadrakula, 309 U.S. 94, 60 S. Ct. 431, 84 L. Ed. 596, 1940 U.S. LEXIS 1066, 127 A.L.R. 821 (1940).

Opinion

Mr. Justice Reed

delivered the opinion of the Court.

This is an appeal from a final judgment of the Supreme Court of New York awarding damages for accidental death; As. .a statute of the state necessarily was sustained against a . contention that its application to these circumstances violated the provisions of the Constitution as to the exclusive authority of the United States over a post-office site purchased with the consent of New York, 1 this Court has jurisdiction under § 237 (a) of the Judicial Code and the Act of January 31, 1928.

The issue of law involved is whether an existing provision of a state statute- requiring the protection of places of work in the manner specified in the statute 2 remains *98 effective as a statute of the United States applicable to the particular parcel after the federal government acquires exclusive jurisdiction of a parcel- of realty on which work is being done.

The decedent, an employee of a rigging company, a sub-contractor engaged in the construction of the New York post office, fell from an unplanked tier of steel beams down a bay and was killed. In an- action of tort against the general contractor, his administratrix narrowed the scope of the charges of negligence until violation of the quoted sub-section of the Labor Law only was alleged. The trial court found that the proximate cause of the accident was the negligent failure to plank the beams as required by the statute. The Appellate Division affirmed 3 on the ground that the Labor Law provision continued effective over the post-office site after the transfer of sovereignty, and the Court of Appeals by an order of remittitur, 21 N. E. 2d 217, also affirmed on the same ground with a statement that in its affirmance it necessarily passed upon the validity and applicability of § 241 (4) of the Labor Law under Article I, § 8 of the Constitution. 280 N. Y. 651, 730; 20 N.E. 2d 1015; 21 N. E. 2d 217.

The language of the Court of Appeals and the record show indubitably that a determinative federal question *99 was decided. 4 The conclusion as to the continued vitality of existing state statutory regulations in the protection of workmen in ceded federal areas makes it substantial. 5 The motions to dismiss or affirm the appeal are denied. 6

If the quoted provision of the Labor Law is operative even though exclusive jurisdiction had already vested in the United States, it is unnecessary to determine whether exclusive jurisdiction had actually passed to the United States. The state courts assumed that federal sovereignty was complete through consent by the state and we make the same assumption. Does the acceptance of sovereignty by the United States have the effect of displacing this sub-section of the New York Labor Law? We think it did not. The sub-section continues as a part of the laws of the federal territory.

It is now settled that the jurisdiction acquired from a state by the United States whether by consent to the purchase or by cession may be qualified in accordance with agreements reached by the respective governments. 7 The Constitution does not command that every vestige of the laws of the former sovereignty must vanish. On the contrary its language has long been interpreted so as to permit the continuance until abrogated of those rules existing at the time of the surrender of sovereignty which govern the rights of the' occupants of the territory trans *100 ferred. 8 This assures that no area however small will be left without a developed legal system for private rights. In Chicago, R. I. & P. R. Co. v. McGlinn, supra, a Kansas statute relating to recovery against a railroad for the injury to livestock on its right of way existed at the time of the cession to the United States of exclusive jurisdiction over Fort Leavenworth Military Reservation. It was held that the statute was carried over into the law covering the Reservation. Conversely, in Arlington Hotel Co. v. Fant, supra, an Arkansas statute relieving innkeepers, passed after cession of Hot Springs Reservation, was held unavailing as a defense to a Reservation innkeeper’s common-law liability in accordance with Arkansas law before the cession. Such holdings assimilate the laws of the federal territory, where the Congress has not legislated otherwise, to the laws of the surrounding state.

The Congress has recognized in certain instances the desirability of such similarity between the municipal laws- of the state and those of the federal parcel. Since only the law in effect at the time of the transfer of jurisdiction continues in force, future statutes of the state are not a part of the body of laws in the ceded area. Congressional action is necessary to keep it' current. Consequently as defects become apparent legislation is enacted covering certain phases. This occurred as to rights of action for accidental death by negligence Or wrongful act. 9 After this statute was held inapplicable to claims under state workmen’s compensation acts further legis *101 lation undertook to extend the provisions of those acts to the pláces under federal sovereignty. 10 With growing frequency the federal government leaves largely unimpaired the civil and criminal authority of the state over national reservations or properties. 11 While exclusive federal jurisdiction attaches, state courts are without power to punish for crimes committed on federal property. 12 This has made necessary the legislation which gives federal courts jurisdiction over these crimes. 13 The tendency toward a uniformity between the federal and surrounding state,-territory has caused a series of congressional acts /adopting the state criminal laws. 14 Through these'concessions our dual system of government works cooperatively towards harmonious adjustment.

It is urged that the provisions of the Labor Law contain numerous administrative and other provisions which cannot be relevant to the federal territory. The Labor Law does have a number of articles. 15 Obviously much *102 of their language is directed at situations that cannot arise in the territory. With the domestication in the excised area of the entire applicable body of state municipal law much of the state law must necessarily be inappropriate.

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Bluebook (online)
309 U.S. 94, 60 S. Ct. 431, 84 L. Ed. 596, 1940 U.S. LEXIS 1066, 127 A.L.R. 821, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-stewart-co-v-sadrakula-scotus-1940.