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Show -102- of a judgment against a state v* This difficulty, however, is inherent in any method of determining interstate differences, and can be overcome by borrowing assistance from the executive 1^- or from Congress <~^ Again though some doubt has been felt ; as to what law will govern ^ precedents are gradually being established * But the chief and seemingly insurmount- aole difficulty is that not all matters in dispute between states are con- sidered as capable of judicial determination c17 Thus a state cannot be compelled to perform an obligation which;, if in question between two nations * could be enforced only through the political depart- 13 Georgia refused to obey the judgment in Chisholm v* Georgia, 2 Ball, (u. S.) 419 (1793) and made it a capital offense for anyone bo undertake to execute it* The potential complications may be appreciated* from a consideration of the final phase of Virginia t, West Virginia. 246 u, s, 565 (1918). Apparently a plaintiff state may be authorized to take possession of disputed territory; a defendant state may be ordered to cease doing acts within the state, Missouri y, Illinois* supra; Kansas v. Colorado, 185 ^« S« 125 (1902) and performance of acts by subordinate officials may be compelled by mandamus or contempt proceedings * Many judgments have also been ren- dered, but until recently the difficulties involved were not consideredo See United States v. North Carolina, 136 U S., 211 (l890) One difficulty is that all the state's property may be devoted to governmental purposes, and the only way of satisfying the judgment will be by appropriation of the state legislature» See George C, Lay, supra, 54. AM. L REV, 705, 714; Carman F. Randolph, supra, 2 COL. L REV. 283, 309* %ut compare Jackson'ar attitude after Worcester v* Georgia^ 6 Peta (TJ* So) 515 (1832)<, See William Co Coleman,' supra, 31 KARV. L. REV. 210s 228 c 15 In Virginia v0 West Virginia, supra, the Supreme Court held it had powers to issue a mandamus to compel West Virginia to pay its debts tm*- re- fused to exercise that power until Congress was first allowed a chance to coerce West Virginia by legislation, West Virginia arranged for payment without further urging0 See JAMES B. SCOTT„ op. cit*, ANALYSIS, 5190 See Rhode Island v« Massachusetts, supra, note 6; South Carolina v* Georgia 93 Uc Se I4 (I876); Missouri v. Illinois, 200 Uc S, k9& (l906)o See also 19 HARV, L. REV, 6065 21 HARV. L. REV. \$2.., 17 'There must be a real dispute between the states, of course* Rights of a citizen or a group of citizens masquerading as states? rights will not be adjudicated. New Hampshire v. Louisiana, 108 U,, S8 76 (1883); South Dakota vo North Carolina 192 Ue S« 286 (190U)0 But see Carman F, Randolph, supra, 2 COL. Lc REV. 283, 292, |