## Facts

- Private parties litigated ownership of land associated with an island area in the Mississippi River near Lake Providence, Louisiana.
- Mississippi citizens brought a federal quiet-title action in the U.S. District Court for the Southern District of Mississippi against Louisiana citizens asserting competing ownership claims.
- The State of Louisiana and the Lake Providence Port Commission intervened in the federal case and asserted that the disputed land lay within Louisiana’s boundary.
- Louisiana filed a third-party complaint against the State of Mississippi in the district-court litigation, raising an interstate boundary and sovereignty dispute.
- Louisiana separately sought leave from the U.S. Supreme Court to file an original bill of complaint against Mississippi to obtain a direct determination of which State had sovereign ownership of the disputed land.

## Issues

1. Whether the Supreme Court should grant Louisiana leave to file an original bill of complaint against Mississippi to resolve an interstate boundary and sovereignty dispute.
2. Whether the existence of related private quiet-title litigation in federal district court counseled against immediate exercise of the Court’s original jurisdiction.

## Decision

- The Supreme Court denied Louisiana’s motion for leave to file an original bill of complaint against Mississippi.
- The Court issued an order without a full opinion and did not reach the merits of the boundary question.
- Justice White dissented, objecting to declining to exercise the Court’s exclusive original jurisdiction over a State-versus-State sovereignty dispute.

## Legal Principles

- Even where an interstate controversy falls within the Supreme Court’s original jurisdiction, the Court may decline to grant leave to file an original action as a matter of docket management and prudential judgment.
- When related proceedings exist in other courts, the Court may decline immediate original-jurisdiction review rather than displacing ongoing litigation.
- An asserted interstate boundary dispute embedded in private litigation can present a sovereignty question that, in a dissenting view, warrants original-jurisdiction adjudication because lower courts cannot conclusively resolve State-to-State boundary rights.

## Conclusion

The Court refused to allow Louisiana to commence an original action against Mississippi at that time, leaving the boundary-related controversy to continue in the existing federal litigation and postponing any Supreme Court merits determination of the interstate sovereignty dispute.


Louisiana v. Mississippi, 488 U.S. 990 (1988)