Testa v. Katt
Citation: 330 U.S. 386 (1947) Court: United States Supreme Court
Facts
Katt, a Rhode Island car dealer, sold a car to Testa at a price above the ceiling set by the federal Emergency Price Control Act of 1942. The EPCA provided for treble damages recoverable in any court of competent jurisdiction. Testa brought suit in Rhode Island state court. The Rhode Island Supreme Court dismissed the action, concluding that Rhode Island courts were not obligated to enforce the penal laws of another sovereign — including the federal government.
Issue
Are state courts required to enforce valid federal statutes that create a private cause of action, even when those statutes are “penal” in nature?
Holding
Yes. The Supreme Court reversed, holding that Rhode Island courts were required to entertain and enforce the federal EPCA penalty action.
Rule / Doctrine
The Full Faith and Credit obligation extends to Acts of Congress: under the Supremacy Clause and congressional command, state courts of competent jurisdiction must enforce valid federal statutes. A state court may not refuse to apply federal law on the ground that the federal law is “penal” or that the state would not enforce a comparable penal law of a sister state. A valid excuse for non-enforcement must come from federal law itself (e.g., if Congress expressly exempts state courts), not from state policy preferences.
Significance
Testa v. Katt is foundational for the principle that state courts serve as enforcers of federal law. It confirms that the Supremacy Clause, combined with congressional intent, can compel state courts to adjudicate federal claims even when state courts would prefer not to. The decision underpins the system of concurrent federal-state jurisdiction and prevents states from nullifying federal rights by refusing to provide a forum.