Subject Matter Jurisdiction Flashcards
Challenging Diversity Jurisdiction
Under federal law, a U.S. District Court has diversity jurisdiction over a matter if no plaintiff shares the state of citizenship of any defendant and the amount in controversy in the case exceeds $75,000. Further, the defense of lack of subject matter subject matter jurisdiction may be raised at any time throughout litigation, as it is not waivable.
Challenging Full Faith and Credit due to Lack of Subject Matter Jurisdiction
Under the U.S. Constitution, state courts are required to give full faith and credit to valid judgments of other states. State courts are likewise required to treat federal judgments as those judgments would be treated by the federal courts. The issues decided in one court cannot be re-litigated in another, and the state in which enforcement is sought must honor the judgment of the federal court. Therefore, a party against whom enforcement of a judgment is sought may collaterally challenge the original state judgment based on lack subject matter jurisdiction only if the jurisdictional issues were not litigated or waived in the original action.
Class Action Fairness Act Diversity Requirements
Diversity in a class action brought pursuant to Rule 23 will generally be determined by the citizenship of the named members of the class bringing the lawsuit. For certain class actions in which the amount at issue totals more than $5,000,000, and the class contains at least 100 members, diversity will be met if any member of the plaintiff class is diverse with any defendant. A corporation is deemed to be a citizen of every state in which it has been incorporated and of the state where it has its principal place of business. A corporation’s principal place of business is generally its corporate headquarters (i.e., its nerve center). An individual is a domiciliary of the state in which he is present and intends to reside for an indefinite period. Additionally, a plaintiff’s good-faith assertion in the complaint that the action satisfies the amount-in-controversy requirement is sufficient, unless it appears to be a legal certainty that the plaintiff cannot recover the amount alleged.
Federal SMJ
Federal question jurisdiction grants the district courts original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States. In general, if the cause of action in question is expressly created by federal law, and federal law provides the underlying right, then federal question jurisdiction will exist. In addition, Congress gave the U.S. district courts diversity jurisdiction over civil actions when the parties to an action are citizens of different states and the amount in controversy exceeds $75,000. Diversity jurisdiction requires complete diversity between opposing parties in a case. There is no diversity of citizenship if any plaintiff is a citizen of the same state as any defendant.
Supplemental Jurisdiction over non-diverse Defendant
A district court with jurisdiction over a claim may exercise supplemental jurisdiction over additional claims over which the court would not independently have subject matter jurisdiction (usually state law claims against a nondiverse defendant) but that are so related to the original claim that the additional claims form part of the same case or controversy under Article III of the U.S. Constitution. In judging whether the claims are related, the test is whether they arise out of a “common nucleus of operative fact” such that all claims should be tried together in a single judicial proceeding.
When is it proper for a district court to deny supplemental jurisdiction when otherwise proper
A district court has discretion to decline to exercise supplemental jurisdiction over a claim that would otherwise qualify for supplemental jurisdiction in each of the following circumstances: i) the supplemental claim raises a novel or complex issue of state law; ii) the supplemental claim substantially predominates over the claims within original federal jurisdiction; iii) all of the claims within the court’s original jurisdiction have been dismissed; or iv) in exceptional circumstances, if there are other compelling reasons for declining jurisdiction.
