Marshall v. Holmes

Marshall v. Holmes, 141 U.S. 589, is an 1891 decision of the United States Supreme Court on equitable relief, res judicata and fraud on the court in diversity jurisdiction. Justice John Marshall Harlan wrote for a unanimous Court that held it unconscionable to allow a state court's decision to stand that had been based on documents later exposed as forgeries. It permitted a federal case seeking to set that verdict aside to go forward.

The petitioner had previously had several judgements rendered against her in Louisiana state court. After discovering that a letter attributed to her, used as evidence against her at trial, had been forged, she filed a petition for a bill of review in the Southern District of New York seeking to enjoin the respondent from endorsing the verdict. The state court would not allow the case to be removed, and so Marshall appealed directly to the Supreme Court.

Harlan's opinion considered both the question of whether federal courts had the authority to so disturb a state court's decision, and whether a court other than that which rendered the original judgement could grant equitable relief in a decided action where allegedly fraudulent evidence had been considered. He held that since Marshall had sought an independent action, Louisiana law and federal precedent allowed the case to be considered. Harlan also dismissed the respondents' argument that federal courts could not hear the case since none of the judgements against Marshall exceeded the $500 minimum then legally required by noting that they well exceeded that amount in the aggregate.