Long Sault Development Co. v. Call

1916-12-18

Headline: Court dismisses company’s federal challenge after state court ruled the 1907 river-use grant unconstitutional, blocking company relief and leaving New York free to control riverbed and navigation improvements.

Holding: The Court dismissed the company’s appeal for lack of jurisdiction because the New York Court of Appeals independently held the 1907 river grant unconstitutional, so no federal contract or takings question arose for review.

Real World Impact:

Company cannot force state treasurer to accept payment after state courts refused relief.
Reinforces state control over riverbeds, limiting private transfers that block future navigation improvements.
Stops federal review when a state court independently invalidates a law on state grounds.

Topics: water rights, state property control, government contracts, federal review limits

Summary

Background

A private company called the Long Sault Development Company was created under a 1907 New York law that granted it rights to build dams, canals, powerhouses, bridges, and to take title to lands under the St. Lawrence River after yearly payments (at least $25,000 after 1911). The company organized, spent money preparing to use those grants, and tendered $25,000 for 1912. The State Treasurer refused the payment after the Attorney General advised the law was unconstitutional. The company asked a court for a writ of mandamus (a court order) to force the Treasurer to accept the payment. The legislature passed a 1913 law repealing the 1907 act while the case was pending.

Reasoning

The central question was whether the federal Constitution protected the company from impairment of contract or property rights by the later law. The Supreme Court examined the New York Court of Appeals’ decision to see whether that court had relied on the 1913 repeal or had independently held the 1907 law invalid. The Court found the state court did not treat the repeal as confiscating the company’s rights. Instead the state court held, under New York law and the public-trust principle for navigable waters, that the 1907 law itself improperly surrendered state control over navigation and was unconstitutional. Because the state court’s ruling rested on those state-law grounds and not on a later repeal that impaired a contract, there was no federal contract-or-takings question for the Supreme Court to decide.

Real world impact

As a result the Supreme Court dismissed the company’s writ of error for lack of jurisdiction. The decision leaves in place the state court’s rejection of the 1907 grant and preserves the State’s authority to control riverbeds and future navigation improvements. This ruling is procedural and does not decide the federal merits; it prevents federal review when a state court independently invalidates a law on state grounds.

Dissents or concurrances

Two Justices (McKenna and Pitney) dissented. They argued the 1907 law created a contract when accepted by the company and that the 1913 repeal impaired that contract in violation of the Constitution, a point they thought the state court’s decision made effective.