Zander v. Coe
Before: Heydenfeldt
Synopsis
The cognizance of all cases, where the sum involved exceeds $200, is Toy the Constitution distributed between the Supreme, District, County and Probate Courts, and the Court of Sessions, and nothing is left by the Constitution for the Legislature to do, in granting or defining jurisdiction.
The disposition of cases, where the sum does not exceed $200, and only these, is left to be prescribed by the Legislature, and they may be vested either in the County Court, under the provisions of the ninth section, or in Justices Courts, under the fourteenth section.
The Legislature can not confer on one Court, the functions and powers which the Constitution has conferred on another.
The law vesting Justices of the Peace with jurisdiction of a case, where the amount in controversy^exceeds S200, is unconstitutional and void.
Heydenfeldt, J., delivered the opinion of the Court. Murray, C. J., concurred.
By statute, the Legislature has conferred jurisdiction on Justices Courts, where the sum in controversy does not exceed five hundred dollars:
The only question raised in this case, is whether the statute is constitutional.
The Constitution provides that, “The District Court shall have original jurisdiction in all cases of law and equity, where the amount in dispute exceeds two hundred dollars.” Art. 6, §6. In Hudson v. Caulfield, 3 Cal., 389, we had occasion to construe this section of the Constitution, and there held, that the jurisdiction thus given was ex[231]clusively original, and that the District Court could not exercise powers which belong to an appellate tribunal.
In that case we remarked, that in the subdivision of power among the different arms of the judiciary, there was an attempt at great care and accuracy, in assigning to each a well-defined portion of official duty. In doing this, there must have been some specific object, or leading motive, and no other appears so reasonable as that it was intended to limit, as well as to confer, jurisdiction, in order the better to secure the independence of this department of government. 3 Cal. 389.
With the decision of that case, and the reasons therefor, we remain satisfied, and so far as we are informed, it has met the entire approbation of the profession.
We here might rest. For if the jurisdiction of the District Court is exclusively “ original in all cases where the amount exceeds two hundred dollars,” and the District Court has only original jurisdiction, it follows irresistibly that, that Court alone can entertain jurisdiction, when the amount in controversy exceeds two hundred dollars; otherwise the construction must be, that the District Court would have original jurisdiction only in cases exceeding two .hundred dollars, but when the amount did not exceed the limited amount, it could exercise original or appellate power, at the will of the Legislature.
These views seem to us conclusive of the case. But the importance of the questions will justify some additional views.
The sixth article of the Constitution seems to have been drawn with great care and skill, and, as far as possible in an organic law, endeavors to establish a complete judicial system. It not only provided for the establishment of the several tribunals, in which the judicial power of the new government was vested, but also distributed among these tribunals, their several powers. To the Supreme Court is given appellate power only; to the District Court, original jurisdiction only; on the Probate Court is conferred the duties of a Surrogate; to the Court of Sessions, criminal jurisdiction; to the County Court, appellate power in cases arising in Justices Courts, and original jurisdiction in such special cases as the Legislature may prescribe. The distribution of power among the several Courts, enumerated in the Constitution,
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