Tracy v. Ginzberg

Background

A man challenged actions by a police board and then a Massachusetts state court about money he said was owed him. The board had created an expectation of payment and set limits on that expectation. The plaintiff asked the state court to declare that money received by another person, Ginzberg, from O’Hearn belonged to him. The state Supreme Judicial Court heard all interested parties and ruled the plaintiff had no right to that money. Specifically, the plaintiff sought a court order saying the money paid by O’Hearn to Ginzberg belonged to him.

Reasoning

The Supreme Court considered whether that state judgment deprived the man of property without fair legal process under the Fourteenth Amendment. The Court emphasized that the claimant’s asserted right grew out of rules set by the police board and was therefore subject to the board’s limits. The Court also explained that a state court’s judgment about who owns property, entered after hearing all parties and applying local and general law, is not automatically a constitutional deprivation. A federal due-process violation requires an arbitrary exercise of power or a departure from long-established legal procedures inherited from English law; the state court’s judgment did not do that.

Real world impact

The ruling affirms that ordinary disputes over ownership decided by state courts, when handled through established procedures, do not become federal constitutional cases. It means unhappy losers in state property fights cannot use the Fourteenth Amendment to turn every state judgment into a federal claim. The Supreme Court affirmed the judgment below.