Chicago, Indianapolis & Louisville Railway Co. v. McGuire

Background

A party that claimed title from a foreclosure and sale conducted in a federal circuit court sought review in the State’s appellate courts and then in this Court. The party argued that the state Appellate Court failed to give full faith and credit (official recognition) to the federal foreclosure decree and sale, and that the disputed property should have been included under the mortgages foreclosed. That federal angle was not clearly presented in the trial court or the Appellate Court, and a later petition to the State Supreme Court for transfer was denied without opinion.

Reasoning

The Court explained that it must dismiss the writ of error because the federal constitutional question was not timely and plainly raised in the lower courts. The Court emphasized the well-established rule that an issue relied on here must have been properly presented and adjudicated below. Because the State courts were not shown to have considered the federal question, and no statute or federal authority was directly challenged, the Court declined to review the constitutional claim now asserted for the first time.

Real world impact

This decision means a party cannot win late access to this Court simply by raising a federal claim after state appeals are over. State-court foreclosure rulings remain in effect when federal issues were not timely pressed below. The ruling is procedural, not a final decision on the merits of the foreclosure or the mortgages, and a properly preserved federal question might still be reviewed in other cases.