Ross v. Oregon

Background

The case involves a bank and several of its officers and directors who held money belonging to Oregon’s educational funds in an account called “educational.” The bank became an active depository in 1907, later failed, and a large shortage of those funds was discovered. One officer was tried, convicted for converting the State’s money under a state criminal statute, and the Oregon Supreme Court upheld the conviction after concluding the deposits were special and the officers’ commingling and use of the funds amounted to unlawful appropriation. While the appeal was pending, the State adopted a constitutional amendment about charging crimes by indictment, which the state court held did not apply to pending cases.

Reasoning

The main question before the United States Supreme Court was whether a federal constitutional right was denied by the Oregon court’s construction of the state depository law or by the state court’s ruling about the later state constitutional amendment. The high court explained that the federal Constitution’s ban on ex post facto laws applies to lawmaking by legislatures, not to a court’s interpretation of a statute. It also said a state court’s decision about how a state constitutional amendment affects pending cases is a matter of state law. Because the record presented no federal question, the Court concluded it had no jurisdiction to review the state-court rulings and dismissed the writ of error.

Real world impact

The dismissal leaves the state conviction intact and affirms that federal courts will not re-decide state courts’ interpretations of their own statutes or of state constitutional changes when no federal issue is presented. This ruling is about federal court jurisdiction, not a decision on the underlying facts or guilt.