Massachusetts v. Missouri

Background

A U.S. state asked permission to file a bill against another State and certain Missouri residents who serve as trustees. The dispute stems from the 1935 death of Madge Barney Blake, who left a small estate in Massachusetts and much larger trusts of securities held and administered in Missouri. Two of the trusts allowed the settlor to revoke them. Massachusetts says both States claim the right to tax the trust transfers, and it sought a Supreme Court decision because the tax cannot be collected from people or property inside Massachusetts.

Reasoning

The core question was whether the Supreme Court should hear the case as an original dispute between States or allow Massachusetts to sue the Missouri trustees here. The Court found no wrongful injury by Missouri that would create a justiciable controversy between the States: the Missouri-held funds appear sufficient, each State’s tax claim can stand independently, and Missouri’s reciprocal exemption law is ordinary legislation, not a binding contract between States. The Court also refused to recast the filing as a simple money claim against the trustees because Massachusetts has other available forums and the Supreme Court should not become a routine trial court for tax collection. The motion for leave to file the bill was denied.

Real world impact

This ruling determines where the dispute must be litigated, not which tax claim is correct. Massachusetts is barred from using the Supreme Court’s original forum here and may pursue collection in Missouri state or federal district courts. The underlying tax questions remain for other courts to decide, and the decision limits the Court’s role in similar interstate tax fights.