omplainant
State must show that it "has suffered a wrong through the action of the
other State, furnishing ground for judicial redress, or is asserting a
right against the other State which is susceptible of judicial
enforcement according to * * * the common law or equity systems of
jurisprudence."[472] The fact that the trust property was sufficient to
satisfy the claims of both States and that recovery by either would not
impair any rights of the other distinguished the case from Texas _v._
Florida,[473] where the contrary situation obtained. Furthermore, the
Missouri statute providing for reciprocal privileges in levying
inheritance taxes did not confer upon Massachusetts any contractual
right. The Court then proceeded to reiterate its earlier rule that a
State may not invoke the original jurisdiction of the Supreme Court for
the benefit of its residents or to enforce the individual rights of its
citizens.[474] Moreover, Massachusetts could not invoke the original
jurisdiction of the Court by the expedient of making citizens of
Missouri parties to a suit not otherwise maintainable.[475] Accordingly,
Massachusetts was held not to be without an adequate remedy in
Missouri's courts or in a federal district court in Missouri.[476]

THE PROBLEM OF ENFORCEMENT; VIRGINIA _v._ WEST VIRGINIA

A very important issue that presents itself in interstate litigation is
the enforcement of the Court's decree, once it has been entered. In some
types of suits, as Charles Warren has indicated, this issue may not
arise; and if it does, it may be easily met. Thus a judgment putting a
State in possession of disputed territory is ordinarily self-executing.
But if the losing State should oppose execution, refractory State
officials, as individuals, would be liable to civil suits or criminal
prosecutions in the federal courts. Likewise an injunction decree may be
enforced against State officials as individuals by civil or criminal
proceedings. Those judgments, on the other hand, which require a State
in its governmental capacity to perform some positive act present the
issue of enforcement in more serious form. The issue arose directly in
the long and much litigated case between Virginia and West Virginia over
the proportion of the State debt of original Virginia owed by West
Virginia after its separate admission to the Union under a compact which
provided that West Virginia assume a share of the debt. The suit was
begun in 1906, and a jud