Anna took her appeal of a Texas ruling to the 9th Circuit Court in California, IIRC based on a discovery issue. Does this mean that if I lose my case in North Dakota, I can take my appeal to New York? Are appeals that political and “free to roam” that I can take my appeal to any court in the nation? What are the rules?
A second question: Are there limits to what I can appeal? From what it sounds, it seems like I can appeal only procedural things. But then again, I’ve understood that in certain states, an “automatic appeal” applies in ‘death sentence’ situations. Am I correct in believing that those appeals are held just to make sure the trial went according to law, without any errors?
I’m thinking my thoughts on the second question are correct, but I’m more curious about the first: can I influence an appeal opinion just by bringing somewhere else?
No. There’s a designated path for appeals. State trial court decisions get appealed to state appellate courts, which usually have two levels, with the second of these levels usually being called the Blank Supreme Court, where “Blank” is the name of the state. In rare situations, a litigant can skip the middle step and appeal directly to the state supreme court.
If there’s a federal question involved, the state supreme court decision can sometimes be appealed to the US Supreme Court. There are also rare occasions where one can file a collateral attack on a state court decision in the Federal system, but these are not technically appeals.
Federal district (trial-level) court decisions get appealed to federal circuit (appellate-level) courts, which can be further appealed to the US Supreme Court.
There are rare exceptions to this.
Different courts have different jurisdictions. These jurisdictional issues involve both personal juridisdiction and subject matter jurisdiction questions. State courts (looked at collectively, in each state) are courts of general subject-matter jurisdiction. They hear any and all kinds of questions. Probate, criminal, divorce, tort, contract, equity – all are within state court jurisdiction. Federal courts, on the other hand, are courts of limited subject matter juridisdiction. To file there, you nearly always need either a federal question, or diversity. Diversity requires that the litigants be from different states. Any overlap between the citizenship of the list of defendants and the list of plaintiffs, and no diversity exists.
There are some special courts that cover specific - and usually very limited - types of cases. These special courts can be in either the federal or state systems. One such court of special jurisdiction is the federal bankruptcy court (or courts). Bankrupcty courts are somewhat of a special case, but are part of the Federal system for subject matter jurisdiction purposes.
In order to promote efficiency, and fully resolve a dispute, federal courts sometimes have the ability to hear state court matters that otherwise would be outside their subject matter jurisdiction, if those matters are somehow connected to the related matter that involves the federal question that triggers Federal subject matter jurisdiction.
That takes care of the generalities. Now for the specifics. First, I know nothing about the Anna Smith case. What follows is based soley on the links in the other thread.
(Note to other law-aware folk: I’m aware that I’m only hitting the high points. For example, I’ve pretty much skipped over personal jurisdiction and federal preemption issues. This is complicated enough already.)
Anna didn’t appeal her Texas case. She seemingly dropped it in some way. Somewhat later, she filed for bankrupcty. That put her automatically in the Federal system. This was not an appeal. She was allowed to file in a California-based Federal court, rather than a Texas-based one, presumably because she could claim California residence. (I’m not a bankruptcy lawyer, and have no time to look it up at the moment.) My best guess is that the original Texas case was filed there because her husband died there, or at least had assets there.
One quirk of bankrupcy law allows parties to file adversary proceedings as part of the bankruptcy case. The bankrupt filer (or her trustee) gets to do so, because any claims she has against third parties are considered assets that should be assembled into the bankruptcy estate. People who have claims against the bankrupt person are allowed to file those claims and have them adjudicated by the bankruptcy estate because the validity of those claims must be determined in order to properly distribute the estate’s assets to creditors.
So Anna got to raise the probate questions in bankruptcy court. (Note: I do not understand why they weren’t precluded under * res judicata* - somehow the Texas court must not have rendered a final decision. This doctrine normally prevents relitigating issues that have already been decided in another court.)
Finally, the “discovery issue” you mention took place in the bankruptcy court, not in the texas court. Anna won on default, because her opponent failed to follow a court rule regarding discovery.
No dispute with Random’s basic analysis. The problem here is that two courts were addressing aspects of the same dispute: a Texas probate court and a California bankruptcy court. It was an appeal from a decision by the latter which went to the Ninth Circuit (see here) and now will be considered by the Supreme Court. As Random acknowledges, though, there are nuances. For more information, see this parallel thread.