In view of the clear acknowledgment by the Supreme Court of the United States that state courts cannot be required to take jurisdiction of actions by the Federal Government for the enforcement of its penal and revenue laws, it seems proper to give further attention to the subject matter of a recent Comment in this Law Review written for the purpose of demonstrating that a state court must take jurisdiction of civil actions for the enforcement by the Federal Government of its penal and revenue laws, unless the jurisdiction of the federal courts is made exclusive by statute.
De Witt Williams,
State Court Jurisdiction of Claims for Federal Penalties, Taxes and Customs Duties,
12 Wash. L. Rev. & St. B.J.
Available at: https://digitalcommons.law.uw.edu/wlr/vol12/iss1/6