Joy v. St. Louis
United States Supreme Court
201 U.S. 332, 26 S. Ct. 478, 50 L. Ed. 776 (1906)
- Written by Heather Whittemore, JD
Facts
Joy (plaintiff) owned property bordering the Mississippi River in St. Louis. The property was granted to the original owner through an act of Congress. Over time, additional land was added to the property through accretion, as gradual deposits of soil were brought to shore by the river. A manufacturing company (defendant) entered the property and claimed to own the property formed by accretion. Joy filed a lawsuit in federal circuit court against the manufacturing company, seeking to eject the manufacturing company and recover damages. Though the question of whether Joy owned the property created through accretion was a question of state law, Joy argued that the federal court had federal-question jurisdiction over the case because title to the land was originally granted through an act of Congress. The circuit court dismissed the case for lack of jurisdiction. Joy appealed, and the United State Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Peckham, J.)
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