Illinois Central Railroad Company v. Adams

This was a bill in equity filed by the railroad company, an Illinois corporation, against Wirt Adams, revenue agent, a citizen of the state of Mississippi, the railroad commission of that state, and the Canton, Aberdeen, & Nashville Railroad Company, a corporation of the state of Mississippi, to enjoin the railroad commission from approving and certifying an assessment for taxes on the Canton, Aberdeen, & Nashville Railroad for any of the years from 1886 to 1897 inclusive; also to enjoin the revenue agent from beginning any suit, or advising any of the counties or towns along the line of such road to bring suit for the recovery of such taxes, and for a decree adjudging such railroad to be exempt from state and county taxation for the years aforesaid.

A temporary injunction, issued upon the filing of the bill, was subsequently discharged, an appeal taken to the court of appeals, which was dismissed for the want of jurisdiction, and a final decree subsequently entered in the circuit court dismissing the bill, with the following certificate upon the questions of jurisdiction:

'1. That the complainant in its original bill showed no jurisdiction on the ground of diversity of citizenship. Defendants claim that its interest was derivative through the Canton, Aberdeen, & Nashville, and that the complainant had no right to raise jurisdiction in the Federal courts by making the Canton, Aberdeen, & Nashville Railroad Company a party defendant in the cause.'

'2. That the complainant by its original bill showed no jurisdiction in this court because of the subject-matter stated, inasmuch as the bill set forth no particular Federal question.'

3. That there was no jurisdiction in this matter, because the bill was a suit against the state of Mississippi and in violation of the 11th Amendment to the Constitution of the United States.

''Messrs. Wm. D. Guthrie, James Fentress, Edward Mayes, Noel Gale, and J. M. Dickinson'' for appellant.

Messrs. F. A. Critz, Marcellus Green, and R. C. Beckett for appellee.

Mr. Justice Brown delivered the opinion of the court: