Murdock v. City of Memphis
United States Supreme Court
87 U.S. 20 (1875)
Murdock (plaintiff) sued the City of Memphis (defendant) in Tennessee state court, alleging his ancestors' 1844 deed conveying land to the city for a naval depot included a reversionary clause returning the property to the grantors if it stopped being used as a depot; the city, however, had conveyed the land to the United States that same year by an unconditional warranty deed with no mention of any reversion, and in 1854 Congress transferred the property back to the city for the city's own use and benefit. Murdock argued the property should have instead reverted to his ancestors under the original conditional deed; the trial court dismissed his complaint, finding the city held perfect title from the United States, and the Tennessee Supreme Court affirmed based on the controlling effect of the congressional transfer act, prompting Murdock's writ of error to the U.S. Supreme Court.
Whether the United States Supreme Court has authority to review a state court decision only if a controlling federal question was decided erroneously and the decision lacked an independent and adequate state ground.