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2. 'Taking State Courts' Principle A contentious obstacle for the Kable majority in implying the Chapter III limitation on State legislative power was the judicially established principle that the Commonwealth Parliament must take State Courts as it finds them.54 This principle was central to the dissents of Brennan CJ and DawsonJ.55 Sections 71 and 77 of the Commonwealth Constitution draw a clear distinction between federal courts and State courts invested with federal jurisdiction.56 For example, under section 77(i), the Commonwealth Parliament may define the jurisdiction of federal courts, while under section 77(iii) it may invest State courts with federal jurisdiction. State courts invested with federal jurisdiction cannot be described as federal courts.57 Nevertheless, the High Court has examined the question of the 'character'58 of State courts invested with federal jurisdiction.59 Previous cases have found that while the constitution and organisation of federal courts is a matter for the Commonwealth Parliament,60 the constitution and organisation ofState courts is a matter for State Parliaments.
